PRIVACY POLICY

Last updated: April 20 2023

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE APP OR OUR SITE.  BY VISITING, ACCESSING, OR USING, THE SITE OR OUR PLATFORM, YOU ACCEPT THIS ENTIRE PRIVACY POLICY.

THE SITE AND PLATFORM ARE INTENDED FOR USERS LOCATED IN THE UNITED STATES, AND THEY ARE NOT INTENDED FOR USERS LOCATED IN ANY OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA.

INTRODUCTION

VirtuEd, Inc. (also referred to herein as “VirtuEd,” “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat the data we collect and process in accordance with applicable law.  We have established this Privacy Policy (the “Policy”) to inform you about the privacy practices that we apply to personal information and inform you about your rights and choices in this regard.

This Privacy Policy (the “Policy”) describes our practices regarding your personal information when you visit the VirtuEd website located at https://virtuedonline.com (the “Site”) or use our online tutoring platform (the “Platform”).  Personal Information means any information or set of information, whether alone or in combination with other Personal Information, processed by VirtuEd, which is sufficient to identify an individual (“Personal Information”). Personal Information does not include information that is anonymous, nor does it include publicly available information that has not been combined with non-public Personal Information.

What processing activities are covered by this Policy?  This Policy applies to the processing of Personal Information when you visit the Site or the Platform and any features, subdomains, content, functionality, services, media, applications, or solutions offered on or through the Site or the Platform.  By accessing and using the Site or the Platform, or by otherwise signaling your agreement when the option is presented to you, you consent to the collection, use and disclosure of information as described in this Policy. This Policy only governs the Site or the Platform, and it does not govern off-line data collection, or any other website or service operated by third parties that do not specifically refer to this Policy. Any materials submitted through the Site or the Platform, and your use of the Site or the Platform are subject to the Terms of Use _______________________________.

“Processing” shall mean any operation or set of operations that is performed upon Personal Information or sets thereof, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction and the verb “to process” shall be construed accordingly.

HOW DO WE COLLECT AND PROCESS YOUR INFORMATION?

We collect and process the following Personal Information from you for the purposes set forth below.

Category	Types of Data and Purpose
Identity Information	Any factual or subjective information about an identifiable individual, which may include, but not be limited to, first name, last name and email address, as well as profile information that you choose to provide for your profile, such as your username, password, preferences, and other information you provide for your profile.  We will collect this Personal Information with your express consent or as otherwise permitted by applicable law. This information is necessary to enable us  to provide you the account you have requested and to maintain the account and your profile.  You may update your account information by editing the information associated with your account.   We process Identity Information to provide the Site and the Platform, to provide our services to you, to honor our terms of use and contracts, to ensure the privacy and security of the Site and the Platform and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of the Site and the Platform and business, the proper management of our customer relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Contact Information	You may provide to us your first name, surname, title, government ID, type, and number, as well as your email address, physical address, and phone number.   We process Contact Information to provide the Site and the Platform, to provide our services to you, to honor our terms of use and contracts, to ensure the privacy and security of the Site and the Platform and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of the Site and the Platform and business, the proper management of our customer relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Social Network Information	You may connect with us through a third-party social network, such as Facebook, Twitter, LinkedIn and other networks (each, a “Social Network”). If you choose to do so, we may collect information from your profile on such Social Network, such as your name, username, and email address. In addition, the Site and the Platform offers features that will allow you to share information from the Site and the Platform to a Social Network or share information from our Social Network sites. If you decide to use such features, they may allow the sharing and collection of information both to and from such Social Network so you should check the privacy policy of each Social Network before using such features.   We process Social Network Information to provide the Site and the Platform and services, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of the Site and the Platform and business and the proper management of our customer relationships.
Cookies and Similar Technologies	When you visit the Site or the Platform, we collect cookies and use similar technologies as described in the “Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies, some areas and features of the Site or the Platform may not work properly. Please see the “Cookies and Similar Technologies” section of this Policy for more information.   We process Cookies and Similar Technologies to analyze use the Site and the Platform and our services, to operate the Site and the Platform, to serve you the content and functionality you request, to ensure the privacy and security of the Site and the Platform and services, to develop new services, to enhance your experience, to track visits to the Site and the Platform, to provide you with a more personal and interactive experience on the Site and the Platform, and for usage analytics. We rely on your express opt-in consent for the use of marketing, performance, and analytic cookies and similar technologies. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of the Site and the Platform, and business.
Usage Data	When you visit the Site and the Platform, we automatically collect information from your browser or device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address, unique device identifier, language preference, device type, browser type, domain server, access time, referring website, mobile network information, data about which pages you visit, support document searches, features enabled for your account, and interactions with other parts of the Site and the Platform.   We process Usage Data to analyze use of the Site and the Platform and our services, to operate the Site and the Platform, to serve you the content and functionality you request, to ensure the privacy and security of the Site and the Platform and services, to develop new services, to enhance your experience, to track visits to the Site and the Platform, and to provide you with a more personal and interactive experience on the Site and the Platform, and for usage analytics. The legal basis for this processing is our legitimate interests in monitoring and improving the Site and the Platform, and services.
Session Contents and Other Communications Data	Users may provide data in connection with their participation in tutoring sessions, including audio, video, chat messages, transcriptions of tutoring sessions, files and other content. Tutoring sessions may be recorded and such recordings may capture your voice and image, amongst other Personal Information. Recordings may be used and shared as described herein or as otherwise disclosed to you prior to such recording.   We process Session Contents and Other Communications Data to analyze use of the Site and the Platform and our services, to operate the Site and the Platform, to serve you the content and functionality you request, to ensure the privacy and security of the Site and the Platform and services, to develop new services, to enhance your experience, to track visits to the Site and the Platform, and to provide you with a more personal and interactive experience on the Site and the Platform, and for usage analytics. The legal basis for this processing is our legitimate interests in monitoring and improving the Site and the Platform, and services.
Location Information	When you visit the Site and the Platform, we may determine your approximate location from your Internet Protocol (IP) address.   We process Location Information to analyze use of the Site and the Platform and our services, to operate the Site and the Platform, to track visits to the Site and the Platform, to provide you with a more personal and interactive experience on the Site and the Platform, and for usage analytics.  The legal basis for this processing is our legitimate interests in monitoring and improving the Site and the Platform and services.
Feedback or Support Inquires, Marketing and Communications Preferences	If you provide us with feedback or respond to surveys, we will collect your name, email address, phone number, marketing preferences, communications preferences, and any written correspondence or comments provided by you.   We process Feedback or Support Inquiries to operate the Site, the Platform, and services, to manage our relationships with you, to improve our customer service, to communicate with you, and to keep records of our communications with you.  The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Contact Us Data	If you contact us, we collect your email address and the content of your correspondence to us.   We process Contact Us Data to operate the Site and services, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to improve our customer service, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site, Platform, and business, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

 

Is entry of personal information required? The entry of Personal Information is required to access certain portions of the Site and the Platform.  You may choose not to provide us with any Personal Information and may still access certain portions of the Site and the Platform but will not be able to access any portions of the Site or Platform that require your Personal Information.

Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information, but once in aggregated form it will not constitute Personal Information for the purposes of applicable law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

Special Categories of Personal Information:  We do not collect any additional “Special Categories of Personal Information” or “Sensitive Personal Information” about you, including, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health.  Nor do we collect any information about criminal convictions and offenses.

 

How do we use the information described in this Policy? To the extent permitted by applicable law, we may use the information described above in order to:

 

• Operate and improve our operations, business, services, and the Site and the Platform;
• Provide you with services, products, content, customer service, and functionality;
• Honor our terms of service and contracts;
• Manage our relationship with you;
• Process and complete transactions;
• Improve our products and services and develop new products and services;
• Maintain our databases and back-ups, including records of our communications with you;
• Ensure the privacy and security of the Site and the Platform, and services;
• Detect fraud and prevent loss;
• Support and improve the Site and the Platform, including evaluations of functionality and features;
• Improve our customer service;
• Communicate with you and respond to your feedback, requests, questions, or inquiries;
• Promote our products and services;
• Market our services and products to you, including by providing more tailored advertising (we will only provide you with marketing-related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time);
• Administer a contest, promotion, or survey;
• Administer rewards, referral, and promotional programs;
• Assess the success of marketing campaigns;
• Analyze use of the Site and the Platform, and our services and prepare aggregate traffic information;
• Recognize your device and remember your preferences and interactions;
• Provide you with a more personal and interactive experience on the Site and the Platform;
• Determine and track user interests, trends, needs, and preferences;
• Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transfers;
• Obtain and maintain insurance coverage, manage risks, and obtain professional advice;
• Accomplish any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your information was provided to us;
• Accomplish another purpose described to you when you provide the information, for which you have consented, or for which we have a legal basis under law;
• Comply with federal, state, or local laws;
• Comply with a civil, governmental, or regulatory inquiry, order, subpoena, summons or process;
• Cooperate with law enforcement agencies;
• Exercise or defend legal rights or claims; and
• Create, use, retain, or disclose de-identified or aggregated data.

 

If we need to use your Personal Information for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

We do not use Personal Information for making any automated decisions affecting or creating profiles other than as described herein.

Marketing Communication Preferences:  We process your Personal Information to contact you with information regarding services that may be of interest to you. You can ask us to stop sending you marketing messages at any time by following the update email preferences or unsubscribe links on any marketing message sent to you or by contacting us at any time using the contact details in the Contact Us section. Please note that we may still find it necessary to communicate with you regarding your use of the Site.

COOKIES AND SIMILAR TECHNOLOGIES

Cookies.  A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

 

First and Third Party Cookies.  The Site and the Platform use 1st party cookies (set by VirtuEd), 3rd party cookies (which are set by third parties), and other similar technologies. First party cookies are set by us (VirtuEd). Third party cookies are set by third parties when you access some content or applications, including advertisements, on the Site and the Platform. These third parties include advertisers, ad networks and servers, content providers, application providers, and social media sites. Unless you set your browser to refuse cookies as described below, these third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you access the Site and the Platform. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising and other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about advertisement or other targeted content, you should content the responsible provider directly. Below is a list of the different types of cookies that we use on the Site and the Platform.

 

Essential Cookies and Similar Technologies. Essential cookies and other similar technologies used by us enable you to navigate the Site and the Platform and use their services and features. Without these essential cookies, the Site and the Platform will not perform correctly, and we may not be able to provide the Site and the Platform to you or provide you with certain services or features of the Site and the Platform.

 

Preference Cookies and Similar Technologies. Preference cookies collect information about your choices and preferences and allow us to remember language and other local settings and to customize the Site and the Platform accordingly.

 

Social Media Cookies and Similar Technologies. Social Media cookies and other similar technologies used by us collect information about your use of social media websites.

 

Other Similar Technologies.  In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. In addition, UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

 

Analytics Cookies and Similar Technologies.  Analytics cookies and other similar technologies used by us collect information about your use of the Site and the Platform and enable us to improve the way they work and operates. Specifically, analytics cookies provide us with information regarding what the most frequently visited pages on the Site and the Platform are, help us record and debug any issues you may have with the Site and the Platform, and show us how effective our advertising is. These analytics cookies do not allow us to see the usage of a single user but does allow us to see overall patterns of usage on the Site and the Platform. We do not examine this information for individually identifying information, but we do use this information to understand the traffic on the Site and the Platform.

 

Advertising Cookies and Similar Technologies. Advertising and other similar technologies used by us cookies are used to display targeting promotions or advertisements based on your use of the Site and the Platform and interests and to manage our use of advertising resources. These cookies collect information about your activities on this and other sites to provide you with interest-based advertising. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

 

Facebook. We use Facebook’s technologies to serve relevant advertisements and to track Facebook ad-driven visitor activity. Facebook Connect also gives you the option to post information about your activities to your profile page to share with others within your network by using a single sign-in service to authenticate your identity. You may learn more about Facebook’s policies by visiting https://www.facebook.com/policy.php, and you can also find instructions for opting out of receiving advertisements via that page.

Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and the Platform and to better understand how they find and use the Site and the Platform. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions. The information stored is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page located at https://support.google.com/analytics/answer/181881?hl=en.

Google Tag Manager. We use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information.  Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.

Google Marketing. We use Google’s marketing technologies (DoubleClick) to track user activity and to serve personalized advertisements. Your browser is assigned a pseudonymous ID, which is used to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, you can visit https://policies.google.com/technologies/ads and https://support.google.com/displayvideo/answer/7621162. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922 and https://adssettings.google.com. Google’s Privacy Policy is available at: https://www.google.com/policies/privacy.

 

Choices About Cookies and Similar Technologies.  You may choose to not allow analytic cookies via the cookies consent banner or you may set your browser to refuse all or some browser cookies or to alert you when cookies are being set.  For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/.  You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.  These settings may affect your enjoyment of the Site’s functionality. Adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. In addition to the above, the links below provide additional information about how to disable cookies or manage the cookie settings:

 

Google Chrome:           https://support.google.com/chrome/answer/95647?hl=en

Firefox:                        https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Microsoft Edge:            https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

Safari:                          https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac  and https://support.apple.com/en-us/HT201265

 

Online Tracking Signals. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on the Site or on third-party websites or online services where we may collect information.

 

Accuracy and Updating Your Personal Information. Our goal is to keep your Personal Information accurate, current, and complete. If any of the Personal Information you have provided to us changes, please update it in your user/account profile, or let us know via the “Contact Us” details at the end of this Policy.  For instance, if your email address changes, you may wish to let us know so that we can communicate with you.  If you become aware of inaccurate Personal Information about you, you may want to update your information.  We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

 

Complaints. If you believe that your rights relating to your Personal Information have been violated, you may lodge a complaint with us by contacting us via the “Contact Us” details at the end of this Policy.

HOW DO WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION?

How and When Is Your Information Shared With Other Parties? We may share your information in the following contexts, but we will not share your Personal Information if such sharing is prohibited by applicable privacy and data protection law. We do not sell, trade or license Personal Information about our users for marketing purposes.

Where permitted by applicable law, we may share the information described above in the following contexts:

Category	Description
Affiliates	We may share your information with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.
Acquisitions and Similar Transactions	We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets. If our business is acquired by or merged with another company, your information may be transferred to the new owners.
Disclosures With Your Consent	We may share your Personal Information to fulfill the purpose(s) disclosed by us when you provided your Personal Information and for which you have provided consent.  We may further ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your information in this context with your consent.
Legal Obligations and Rights (Subpoenas, Court Orders, and Warrants)	We may disclose information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our legal rights or claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts.
Third Parties	We may provide information about you to third parties that may offer products and services specifically requested by you.
Service Providers	We may share information with our service providers and contractors that need access to information to provide operational or other support services on our behalf. Among other things, service providers help us to administer the Site and the Platform; support our operations; provide technical support; send communications to you; provide payment processing; and assist with other legitimate purposes permitted by law.
Professional Advisors	We may share your information with our and our affiliates’ insurers and professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf.
Deidentified or Aggregated Data	We may disclose aggregated information or de-identified information that does not identify any specific individual, such as groupings of demographic data or customer preferences.

 

HOW LONG DO WE STORE AND USE YOUR INFORMATION?

We retain and use your Personal Information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to pursue legitimate business purposes, to enforce our agreements.

We take reasonable steps to delete the Personal Information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your Personal Information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your Personal Information if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Information is contrary to our legal obligations or business objectives.

To the extent permitted by law, we may retain and use anonymous, de-identified, aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.  When we delete data, it will be removed from our active servers and databases; but it may remain in our archives when it is not practical or possible to delete it.

We are required by law to maintain records of consumer requests submitted under the California Consumer Privacy Act and how we responded to such requests for at least twenty-four (24) months.  We only use this information for recordkeeping purposes.  If you are a resident of California, please see the California Residents section for more information.

HOW DO WE PROTECT YOUR INFORMATION?

We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technologies and methods.  While our security measures seek to protect the Personal Information in our possession, no security system is perfect, and no data transmission is 100% secure.  As a result, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of any information you transmit to or from the Site. Your use of the Site is at your own risk.  We cannot guarantee that your data will remain secure in all circumstances.

We have implemented reasonable security measures to detect fraudulent identity-verification activity and to prevent the unauthorized access to or deletion of Personal Information.  Key VirtuEd business systems are CCPA, and CPRA compliant and are otherwise compliant in accordance with industry best standards and applicable law. Systems and processes have been scrutinized for limiting access to only required personnel, and the proper protections and restrictions to physical accessibility have been implemented to secure your Personal Information from accidental loss and from unauthorized access, use, alteration or disclosure.  We use reasonable security measures when transmitting Personal Information to consumers in responding to requests under the California Consumer Privacy Act.

The safety and security of your Personal Information also depends upon you.  Where you use a password for access to restricted parts of the Site, you are responsible for keeping your password confidential.  Do not share your password with anyone.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

How does VirtuEd protect children’s information?

Protecting the privacy of young children is especially important to VirtuEd. For that reason, we have created certain features designed to help protect Personal Information relating to children who are less than 13 years of age (“Children” or each, a “Child”). For example, notwithstanding anything to the foregoing, we will not use data from Children for any advertising purposes.

VirtuEd does not knowingly permit Children to use our Site or Platform without prior, express consent from a parent or legal guardian in accordance with or as otherwise permitted by COPPA, as set forth more fully in this Policy. If we learn that Personal Information of a Child has been collected on our Site or Platform without prior parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with our Site or Platform without your consent, please contact VirtuEd using the “Contact Us” details provided at the end of this Policy to request that we delete that Child’s Personal Information from our systems.

YOUR RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor such requests when we are required to do so under applicable law.

Email Opt-Out. We may send you emails about our services and other updates. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at via the “Contact Us” details at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action. Please note that registered users cannot opt out of receiving transactional e-mails related to their account.

Accuracy and Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. If you have created a user account, you may access, review, and make changes to your registration by following the instructions on the Site or the Platform; however, your e-mail address cannot be changed from that used in your initial registration. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Right of Access.  If required by law, upon request, we will grant reasonable access to the personal information that we hold about you.

Right to Erasure and Deletion of Your Personal Information. You may have a legal right to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your personal information has been unlawfully processed.  All deletion requests should be sent to the address noted in the Contact Us section of this Policy.

Right to Withdraw Consent.  If you have provided your consent to the collection, processing, and transfer of your personal information, you have the right to fully or partially withdraw your consent.  To withdraw your consent, please notify us using the information in the Contact Us section of this Policy, and you may follow opt-out links on any marketing communications sent to you.

Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

Nevada Residents. You may submit a verified request to us at ______________________ to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request. We will respond to your request in accordance with Nevada law.

CALIFORNIA RESIDENTS

CCPA and CPRA Notice at Collection. For purposes of the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), in collecting the information described above, we collect the categories of Personal Information listed below.

CCPA/CPRA Category	Description
Identifiers	When collecting Account Information, we will receive your name, email address, username, and unique personal identifier.   When collecting Social Media Information, Feedback or Support Inquiries, and Contact Us Data, we will receive your name and email address.   When collecting Social Media Information, we will receive your name and email address.   When collecting Cookies and Similar Technologies and Usage Information, we will receive your Internet Protocol (IP) address or unique device identifier.   We use Identifiers as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Categories of personal information described in the California Customer Records statute	When collecting Account Information, we will receive your name, email address, username, and unique personal identifier.   When collecting Social Media Information, Feedback or Support Inquiries, and Contact Us Data, we will receive your name and email address.   When collecting Social Media Information, we will receive your name and email address.   When collecting Cookies and Similar Technologies and Usage Information, we will receive your Internet Protocol (IP) address or unique device identifier.   We use Categories of Personal Information described in the California Customer Records statute as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Internet or other electronic network activity information	When collecting Cookies and Similar Technologies and Usage Information, we will receive data about which webpages you visit.   When collecting Location Information and Usage Information, we will automatically receive information from your browser and your device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address, domain server, browser type, access time, and data about which pages you visit.   We use Internet or Other Electronic Network Activity Information as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Geolocation data	When collecting Cookies and Similar Technologies, Location Information and Usage Information we will receive your location while using the Site.   We use Geolocation Data as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Audio, electronic, visual, thermal, olfactory, or similar information	We use Audio, electronic, Visual, Thermal, Olfactory, or Similar Information as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Commercial Information	When collecting Contact Us Data, we will receive your preferred method of contact and the message that you choose to provide.   We use Commercial Information as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Professional or employment-related information	When collecting Account Information and Contact Us Data, we will receive your work email address, work telephone number, company name, and company address.   We use Professional or Employment-Related Information as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Inferences	Examples: Derivation of information, data, assumptions, or conclusions from facts, evidence, or another source of information or data) drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

DATA PRACTICES DURING THE LAST 12 MONTHS

Personal Information Collected: We have not collected any categories of Personal Information listed in this Policy during the preceding 12 months.

Categories of Sources: We will collect Personal Information identified in this Policy from you directly when you provide it to us, automatically as you  navigate through the Site, which may include, but not be limited to, usage details, IP addresses, and information collected through cookies and other tracking technologies, and from our business partners, as applicable.

Business and Commercial Purposes for Collecting: We will collect the categories of Personal Information listed above for the following purposes:

 

• Operate the Site;
• Provide our services to you;
• Honor our terms of use and contracts;
• Ensure the privacy and security of our Site and services;
• Maintain our databases and back-ups;
• Manage our relationships with you;
• Communicate with you;
• Keep records of our communications with you;
• Analyze use of the Site and our services;
• Serve you the content and functionality you request;
• Develop new services;
• Enhance your experience;
• Track visits to the Site;
• Provide you with a more personal and interactive experience on the Site; and
• Usage analytics purposes.

Personal Information Sold or Shared: We have not sold or shared categories of Personal Information or Sensitive Personal Information during the preceding 12 months.

Sensitive Personal Information Collected:  We do not collect Sensitive Personal Information for any purpose.

Sensitive Personal Information Disclosed, Sold, or Shared:  We do not currently and have not disclosed, sold or shared categories of Sensitive Personal Information during the preceding 12 months.

Personal Information Disclosed for a Business Purpose. We have not disclosed for a business purpose any categories of Personal Information.  To the extent we so collect such information, they may include:

• Identifiers
• Categories of personal information described in the California Customer Records statute
• Characteristics of protected classifications
• Commercial information
• Internet or other electronic network activity information
• Commercial Information
• Geolocation data

If applicable, we may disclose each category of Personal Information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) contractors and service providers (data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (4) operating systems and platforms.

Personal Information Retention.  We will store your Personal Information for as long as is reasonably necessary to fulfill the purposes described in this Policy or as required by law.

CHILDREN

VirtuEd does not collect or maintain Personal Information on any minors under the age of 16, except with express parental/legal guardian consent as more fully set forth in the Privacy Policy and Parental/Legal Guardian Notice and Consent. We do not knowingly sell or share Personal Information of minors under 16 years old, however, to the extent we knowingly “sell” or “share” as those terms are defined under the CCPA and the CPRA, respectively, the Personal Information of minors under 16 years old who are California residents, we either obtain prior affirmative authorization from such minor to the opt-in to the sale of the minor’s Personal Information or obtain affirmative authorization from the minor’s parent or guardian. A minor, or parent/guardian, who has opted in to the sale of the minor’s Personal information has the right to opt-out at any time. To exercise your right to opt-out see the Right to Opt-Out section below. See also the Submitting a Request and Right to Delete sections with regard to Personal Information of any minors under the age of 16.

RIGHT TO OPT-OUT/DO NOT SELL OR  MY PERSONAL INFORMATION OR SENSITIVE PERSONAL INFORMATION

Under the CCPA and CPRA, you have the right to direct us to stop selling and sharing your Personal Information to third parties and to refrain from doing so in the future. To the extent we sell or share your Personal Information, as those terms are defined in the CCPA and CPRA, respectively, you have the right to opt-out of the sale or sharing of your Personal Information at any time.  You may submit a request to opt-out using the link on our website, or by contacting or us at ____________________ or by email at ____________________________. For purposes of the CCPA and the CPRA, we do not sell or share Personal Information or Sensitive Personal Information as defined under applicable law.

 

FINANCIAL INCENTIVES

We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your Personal Information.

REQUESTS TO KNOW,  REQUESTS TO DELETE, AND REQUESTS TO CORRECT

The CCPA and CPRA gives consumers the right to request that we (1) disclose what Personal Information we collect, use, disclose, sell, and share and (2) delete certain Personal Information that we have collected or maintain. You may submit these requests to us as described below, and we honor these rights where they apply.

 

If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (1) treat the request as if it had been submitted in accordance with the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.

 

Request to Know. As a California resident, you have the right to request: (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected about you; (3) the categories of sources from which the Personal Information is collected; (4) the categories of Personal Information about you that we have sold or shared and the categories of third parties to whom the Personal Information was sold or shared; (5) the categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom the Personal Information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, selling, or sharing Personal Information; and (7) the categories of third parties with whom we share Personal Information. Our response will cover the 12-month period preceding our receipt of a verifiable request, except as otherwise required by applicable law.

 

Request to Delete. As a California resident, you have a right to request the erasure/deletion of certain Personal Information collected or maintained by us. As described herein, we will delete your Personal Information from our records and direct any service providers (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law, for example, when it is necessary for us to maintain your personal information in order to:

 

• Complete the transaction for which the personal information was collected;
• Fulfill the terms of a written warranty or product recall conducted in accordance with federal law;
• Provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you;
• Otherwise perform a contract between us and you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Comply with the California Electronic Communications Privacy Act;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with a legal obligation; and
• Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which the information was provided.

 

Request to Correct.  As a California resident, you have a right to request the correction of certain inaccurate Personal Information collected or maintained by us. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the inaccurate Personal Information as directed by you, pursuant to applicable law.

 

Right to Limit Use and Disclosure of Sensitive Personal Information

As a California resident, you have a right to request that use and disclosure of Sensitive Personal Information be limited to that use which is necessary to perform the services or provide the goods reasonably expected by a similarly situated consumer and as authorized in accordance with applicable law.  You further have the right to opt-out of the selling or sharing of your Sensitive Personal Information.  See the Right to Opt-Out section for further instructions as to how to Opt-Out.

 

Submitting a Request

 

Submission Instructions. You may submit a request to know or to delete via your Account Page or a toll-free telephone call to _____________________ or by email at ________________________.  Regarding requests to delete, we may present you with the choice to delete select portions of your Personal Information, but a global option to delete all Personal Information will be offered and more prominently presented.

 

Verification Process. We are required by law to verify the identities of those who submit requests to know or to delete. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name and email address. We will inform you if we cannot verify your identity.

 

• If we cannot verify the identity of the person making a request for categories of Personal Information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.
• If we cannot verify the identity of the person making the request for specific pieces of Personal Information, we are prohibited from disclosing any specific pieces of Personal Information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.
• If we cannot verify the identity of the person making a request to delete, we may deny the request.
• If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.

 

Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with signed permission to do so; (2) verify your identity directly with us; and (3) directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.

 

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

 

Time Period to Comply with Requests.  VirtuEd will disclose and deliver the required information as requested by you pursuant to this Section free of charge, correct inaccurate personal information, or delete your personal information, based on your request, within 45 days of receiving a verifiable request, but will confirm receipt of your request within 10 business days of receipt of same. We will promptly take steps to determine whether the request is a verifiable consumer request, as set forth herein, but this shall not extend our duty to disclose and deliver the information, to correct inaccurate personal information, or to delete personal information within 45 days of receipt of the request. However, the time period to provide the required information, to correct inaccurate personal information, or to delete personal information may be extended once by an additional 45 days when reasonably necessary, provided we provide you with notice of the extension within the first 45-day period.

 

CCPA NON-DISCRIMINATION

You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA and CPRA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers for exercising their rights under the CCPA.

CALIFORNIA SHINE THE LIGHT

Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at _____________________.

Nevada Residents

You may submit a verified request to us at _________________________ to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.  However, please know that we do not currently sell data triggering the Nevada statute’s opt-out requirements.

 

Colorado, Connecticut, Virginia, and Utah Residents

If you are a resident of Colorado, Connecticut, Utah or Virginia, you may have certain privacy rights under the applicable privacy laws in your state (“State Privacy Laws”). This section describes those rights and how you can exercise them with VirtuEd.

 

Rights Requests

 

Right to Know, Right to Deletion and Right to Correct

 

You can request what Personal Information we have collected, used, disclosed, and sold.

 

You can request to correct inaccuracies in your Personal Information, taking into account the information’s processing purpose.

 

You can opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects including, but not limited to, automated processing performed on personal information to evaluate, analyze or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location or movements (“Profiling”). To submit a request to opt out pursuant to this section, please contact us using the information provided in the Contact Us section of this Policy.  To opt out of cookie-based or digital advertising-based Profiling, please opt out of the selling/sharing of your information for targeted advertising, as described above. Note that if you opt out of profiling, your experience with VirtuEd will be less personalized.

 

We will not be able to opt you out of Profiling where one of the following exceptions applies:

 

• Legal: To comply with applicable laws, rules or regulations; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by governmental authorities; to cooperate with law enforcement; to investigate, exercise, prepare for or defend actual or anticipated legal claims; or to assist another party with any of its obligations under applicable laws;
• Security: To prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, or malicious, deceptive, or illegal activity; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;
• Improvement of Services and Products/Internal Use: To conduct internal research to improve, repair or develop products, services or technology;
• Transactional: To provide a product or service specifically requested by you; to complete a transaction with you or to complete a contract we have with you; and
• Public Interest: To protect your vital interests or those of another individual.

 

You can also request that we delete your Personal Information. We may not delete all of your Personal Information if one of the following exceptions applies:

 

• Transactional: To complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;
• Security: To detect data security incidents; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;
• Error Correction: To debug or repair any errors;
• Legal: To protect against fraud, harassment, malicious or deceptive activities, or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; to assist another party with any of its obligations under applicable privacy laws; or
• Internal Use: To use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e., to improve our services).

 

Right to Appeal

 

If you are a Colorado, Connecticut or Virginia resident and we were unable to fulfill your request, you may appeal our request by contacting us using the information provided in the Contact Us section of this Policy within fourteen days of our decision, and submitting an appeal request, with a detailed reason for your appeal, as well as your state of residence.

 

Retention

 

We will store your personal information for as long as is reasonably necessary to fulfill the purposes described in this Privacy Policy or as required by law.

 

To exercise any of these rights or to appeal a decision regarding a consumer rights request, please Contact Us using any of the methods listed in Contact Us section of this Policy.

 

THIRD-PARTY SITES AND SERVICES

This Policy only applies to the Site and the Platform, and it does not apply to any third-party websites or applications.  Tutor payments are handled directly by third-party vendors. These vendors may use your payment data in accordance with their own privacy policies.  Please visit https://stripe.com/privacy for more information.

In addition, the Site and the Platform may contain links to, or media and other content from, third-party websites. These links are to external websites and third parties that have their own privacy policies. If you follow any links that direct you away from the Site and the Platform, including links to social media sites or to other websites, this Policy will not apply to your activity on the other sites you visit. Because of the dynamic media capabilities of the Site and the Platform, it may not be clear to you which links are to the Site and the Platform and which are to external, third party websites. If you click on an embedded third-party link, you will be redirected away from the Site and the Platform to the external third-party website. You can check the URL to confirm that you have left the Site and the Platform.

We cannot not (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (ii) control the privacy policies or the privacy practices of any third parties regarding their independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on the Site and the Platform.

Any Personal Information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet.  We do not knowingly collect or solicit any Personal Information from children under the age of thirteen (13), except with the appropriate consent as set out herein and in VirtuEd’s Privacy Policy and Parental/Legal Guardian Notice and Consent. Children under the age of thirteen (13) are prohibited from using the Site or the Platform unless they are doing so with parental consent in compliance with COPPA. If we learn that we have collected Personal Information from a person under the age of thirteen (13) that does not comply with COPPA, we will delete that information as soon as reasonably practicable. If you believe that a child under the age of thirteen (13) has provided Personal Information to us without the necessary consent, please contact us via the “Contact Us” details provided at the end of this Policy.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

UPDATES AND CHANGES TO THIS POLICY

We reserve the right to add to, change, update, or modify this Policy at any time to reflect any changes to how we treat your information or in response to changes in law. In the event we make changes to this Policy, such policy will be re-posted on this page, with the date such modifications were made indicated on the top of the page. If we make material changes to how we treat your information, we may contact you to inform you about the revisions with a link to the revised Policy or notify you through a notice on the homepage of the Site and the Platform for a reasonable period of time. All changes are effective on the date listed at the top of this page and will apply to all information that we have about you.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site and the Platform, and from time to time, so that you are aware of any changes. Your continued use of the Site and the Platform, or our services after the “Last Updated” date indicates your acceptance of the changes and your continued consent to our processing of your Personal Information according to the terms of the then-current Policy. If at any point you do not agree to any portion of this Policy, then you should immediately stop using the Site and the Platform, and the services. Because this Policy contains legal obligations, we encourage you to review this Policy carefully.

CONTACT US

For more information, or if you have any questions concerning this Policy or our information collection, storage and disclosure practices, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.

In Writing:

By Phone:    

By Email: [email protected]

When you contact us, please describe in as much detail as possible the nature of your inquiry. We will investigate your inquiry promptly.