Privacy Policy

Last Updated: March 15, 2023
 

This Privacy Policy describes how TUTORINGEZ, Inc. (referred to as “TUTORINGEZ”, “our”, “we” or “us” in this Policy) collects, uses, shares, and protects your personal information, what choices you have relating to your personal information, and how you can contact us. 

 

Contents

1. Scope of this Privacy Policy

2. Personal Information We Collect

3. How and Why We Use Your Information

4. How We Disclose and Share Personal Information

5. Your Sharing

6. Children’s Privacy

7. Protection of Personal Information

8. Retention of Personal Information

9. Managing Your Privacy Rights and Choices

10. About Cookies and Similar Technologies

11. Using the TUTORINGEZ Platform with Third-Party Products and Services

12. Changes to Our Privacy Policy

13. Questions, Feedback and Metrics

14. Additional State-Specific Information

 

1.        Scope of this Privacy Policy

 

This Privacy Policy (“Policy”) applies to the personal information that TUTORINGEZ, Inc. collects and processes when you interact with us as a customer, including when you interact with our websites, digital experiences, mobile apps, stores, online or offline events, promotions, or one of our other products or services, all of which are part of TUTORINGEZ’s “Platform” and direct to this Privacy Policy. This Policy also applies to the personal information that TUTORINGEZ processes when you subscribe to receive marketing communications from us, communicate with us or engage with us via our Platform, or participate in contests, sweepstakes, and surveys.

TUTORINGEZ may provide you with additional privacy notices that will apply to certain personal information collected and processed by us. For example, we may provide additional notice to provide more specific information if you choose to take advantage of a particular partner promotion.  This Policy does not apply to your personal information if you work for us as an employee or independent contractor, apply for a job at TUTORINGEZ, or interact with third party partners or websites that are linked to or accessible from TUTORINGEZ’s Platform.

 

2.        Personal Information We Collect

 

TUTORINGEZ collects personal information directly from you, automatically when you use our Platform or interact with us, and from third parties.   The definition of “personal information” depends on the applicable law of where you reside. For purposes of this policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household.  This does not include aggregated or de-identified information that is maintained in a form that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual or household.

 

Personal Information Collected Directly from You.

We ask you for certain personal information to provide you with the products or services you request. The personal information we collect from you depends on how you interact with us or use our Platform. This personal information includes your:

• Identifiers. We collect certain personal information from you, such as your name, telephone number, email address, date of birth, password, and other identifiers, as well as any personal and demographic information that you share with us, such as gender, hometown, photos, and images you provide to us or post to your profile, or product preferences. When you make a purchase, we collect your payment or credit card information and shipping and billing address.

• Commercial Information. We collect information about your purchases, favorites, and items that you view or add to your cart.

• Communications. When you communicate with us, we collect your contact details and keep a record of the communications, as well as our responses. We also maintain records of information that you post on our social media channels, and information you provide to us related to any customer support requests.

• Physical Characteristics. We collect information on your physical characteristics, including weight, height, and body measurements (such as estimated stride and shoe/foot measurements or apparel size).

• Fitness and Activity Information. We may collect fitness activity information provided by you or generated through your use of our Platform, such as time, duration, distance, location, calorie count, resting heart rate and pace/stride. We may also collect information from your device’s health and fitness repository (such as Apple’s HealthKit or Android’s Google Fit).

• Sweepstakes, Contests and Promotions. If you participate in sweepstakes, contests, and promotions that we offer, we may collect your personal information and other registration information related to contests, sweepstakes, and promotions.

• Events Information. We also collect personal information related to your participation in our events. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event.

 

Personal Information We Derive or Collect Automatically.

We and our third-party service providers automatically collect personal information related to your use of our Platform and interactions with us and others, including when you enable certain features within our Platform. This information includes:

• Location information. We may collect or derive approximate or precise location information about you. How we collect this information depends on how you use and interact with our Platform and your device settings. For example, we may derive your general location through your IP address.  We may collect your precise geolocation (GPS) information from your device or browser, including with your permission available via your device or browser. You may turn off precise location information sharing through your device settings.

• Device information. When you interact with our Platform, we collect technical information about your device including your IP address; unique identifiers; unique device identifier and device type; domain, browser type, version, and language; operating system and system settings; general location information and time zone; and similar device and usage information.

• Online Activity and Browsing Information. We use cookies, log files, pixel tags, software development kits (“SDKs”) and other tracking technologies to automatically collect information about your interaction with our websites and apps and communications you receive from us. This information includes links clicked, page views, purchases, searches, features used, items viewed, time spent within the Platform, information uploaded, items you add to your cart and your interactions with others within the Platform. 

• Audio, visual and other electronic data. We may collect audio, visual, and other electronic data, such as through CCTV footage from our stores, offices or premises, and call recordings.

• Sensor and Movement Data. When you grant us access, we may collect information about you from your device’s sensors, including heart rate, and information about your movement and travel patterns from your device’s accelerometer.

• Photos, Contacts, and Calendar information. When you grant us access, we may collect your photos, contacts and calendar information stored on your device.

• Inferences. To personalize your experience on the Platform, we may draw inferences using your personal information, to create a profile reflecting your interests, preferences, and characteristics.

 

Personal Information from Third Parties.

We may collect personal information about you from third party sources, including when you use our Platform with third party products and sources. This includes:

• Information from Third Party Products and Services. If you connect your TUTORINGEZ account or access our Platform through third party products or services (such as app stores or social media platforms), we may collect information about you from that third party product or service.

• Information from Partners. With your consent where required, we may obtain information about how you participate or engage with marketing campaigns and/or events that TUTORINGEZ sponsors jointly with third party partners.

 

Third-party products and services may control the information they collect and share about you. For information about how these third parties may use and disclose your information, please consult their respective privacy policies.

 

3.        How and Why We Use Your Information

 

TUTORINGEZ collects, uses, discloses, and otherwise processes the personal information we collect for the following business and commercial purposes:

• To Provide the Features of the Platform and the Services You Request. When you use our Platform, we will use your personal information to provide the requested product or service. For example, if you make a purchase on TUTORINGEZ.com, we will use your personal information to fulfill your order and complete the transaction. If you participate in a promotion, we will use the contact information you give us to communicate with you about the promotion. If you contact our consumer services, we will use information about you, such as delivery or payment information, or the product you have purchased, to help you resolve a problem or question. If you use our Platform to track your fitness activity or physical characteristics, we will collect this personal information and store it so that you can review it in the Platform. Your fitness activity information may include information you enter about your activity or data collected by your device during your activity such as location and movement information. We may use this activity information to calculate further information about your activity, such as distance run, or calories burned, so that the calculated information can be provided to you as part of the functionality of the Platform. In many cases, to use particular features within our Platform you may need to provide TUTORINGEZ with additional information or additional consent to use particular information in a certain way. For example, to use the heart rate tracking features of our Platform, you may need to connect to a heart rate monitoring device. Similarly, to share content on social media, you may be required to provide your social media account credentials to sign in.

• To Send Marketing and Communicate Information about our Products, Services, Events and for Other Promotional Purposes. If you are an existing customer of TUTORINGEZ (for example, if you have placed an order with us), we may use the contact details you provide to send you marketing communications about similar TUTORINGEZ products or services, where permitted by applicable law (unless you have opted out). In other cases, we ask for your consent to send you marketing information.  Except for fitness and activity information (including Workout Info, defined below), we may use the information that you provide to us as well as information from other TUTORINGEZ products or services, such as your use of TUTORINGEZ’s Platform, to personalize communications and advertisements regarding our products and services that may be of interest to you. This may include information collected from your interactions with our Platform that are associated with your account across devices. We may also use information for event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and services.

• For Research, analytics, and improvement. We use information to better understand how consumers engage with the Platform and our products and offerings, including consumer behavior and preferences. We administer surveys and questionnaires, such as for market research or member satisfaction purposes.We also use information for other research and analytical purposes, such as to evaluate and improve our Platform and business operations, to develop services and features, and for internal quality control and training purposes. For example, we may use information about how consumers engage with TUTORINGEZ.com to search for and find products, to better understand the best ways to organize and present product offerings in our storefront.

• To Personalize Your Experience and Our Platform. We use personal information, including inferences drawn from your personal information, to tailor and personalize your experience on our Platform.

• To Operate, Improve and Maintain our Business, Products and Services. We use the personal information you provide to us to operate, improve, and maintain our business, products, and services. We may use personal information about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our Platform. We also use information to consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and as related to the administration of our general business, accounting, auditing, compliance, recordkeeping, legal and other internal functions.

• To Protect Our or Others’ Rights, Property or Safety. We use information to protect the Platform and our business operations; to protect our rights or those of our stakeholders; to prevent, detect and investigate actual or suspected fraud, abuse, illegal use, unauthorized or illegal activities and access and other misuse; and where we believe necessary to investigate, prevent or take action regarding situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use.

• To Comply with Legal Obligations. We may also use your personal information as part of legal proceedings, to respond to legal process, and to comply with court orders, governmental requests, or applicable law.

• For Account Linking. If you consent to link your TUTORINGEZ account with a membership account at a TUTORINGEZ partner, TUTORINGEZ will obtain personal information from the TUTORINGEZ partner, including your purchases and returns.  We use this information to give you access to selected benefits, such as access to exclusive TUTORINGEZ products, rewards, and experiences, when you shop with our partners.  TUTORINGEZ will also use the personal information to personalize your experience on the TUTORINGEZ Platform and to send your personalized marketing communications. 

• Other purposes. We may also use your personal information in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

  

4.    How We Disclose and Share Personal Information 

 

TUTORINGEZ may disclose and share personal information we collect with the following types of entities and recipients:

• To our affiliates, subsidiaries, vendors, and service providers. We may disclose personal information to our affiliates and subsidiaries, as well as service providers, vendors and others for business purposes and to perform functions on our behalf (such as those who process credit cards and payments, perform shipping and deliveries; host, manage and service our data; provide technical support or logistics services; secure our Platform; distribute emails; perform research and analysis; manage brand and product promotions; and administer certain services and features on our Platform). 

• To other Platform users. Your username and any information that you post to our Platform, including, without limitation, reviews, comments, and other text, will be available to, and searchable by, other users of the Platform. You can review and make changes to who can view your profile in your account settings.

• Third Party Partners Connected to Your Membership. If you are a TUTORINGEZ member, we may disclose your personal information to third parties that we work with to bring you special offers or who may contact you about products, services and offers you may be interested in. TUTORINGEZ enables you to connect our Platform or link your Membership with third party memberships, products, and services. If you choose to connect your TUTORINGEZ account or membership, we will share certain personal information with third party partners who may process your personal information in accordance with the privacy policies of those third parties. The information may include information generated through your use of the Platform (such as profile, fitness and activity, and purchase information).

• To Third-Party Advertising and Social Platforms and Networks. We may disclose or make available personal information to third-party platforms and providers to obtain personalized and tailored advertising services, to provide or make available certain features or portions of the Platform, or as necessary to respond to your requests. For example, we make information collected via cookies and similar technologies on our Platform available to third-party advertising companies to serve you with relevant ads and content and to manage, improve and measure our advertising campaigns. We also use third party services to match information that we hold with personal information in their database to create custom audiences and tailor advertising to your interests on the Internet, including social media, as permitted by applicable law.  Providing tailored advertising services may be considered a “sale,” “sharing” for cross-context behavioral advertising, or “targeted advertising,” as defined by applicable law. We do not disclose, sell, or share personal information to third parties for money­ or compensation. You may opt-out of cross-context behavioral advertising or targeted advertising by using the relevant settings available in our Platform

• Retail Store Partners. We may share your personal information with partners of our TUTORINGEZ retail stores to help them manage in-store activities and events. For example, TUTORINGEZ may share a list of attendees with the partners who organize an event.

• Business partners and potential buyers (and their agents and advisors). We may disclose your personal information with actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, provided that we inform the buyer or transferee that it must use your personal information only for the purposes disclosed in this Privacy Policy.

• Other Parties. We may disclose personal information to other parties, including government entities and regulators, to the extent necessary to: (i) comply with a government request or applicable law and to respond to legal process; (ii) prevent illegal uses of our Platform or violations of our Platform's Terms of Use and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting).

• With your consent. We may disclose your personal information to any other third party where you have provided your consent.

 

5.        Your Sharing

 

When you use certain social features on our Platform, you can make your profile public that may include information such as your screen name, profile picture and hometown. You can also share content with your friends or the public, including product reviews and information about your TUTORINGEZ activity. This content, including any information that you post to our Platform, will be available to other users of the Platform. We encourage you to use the tools we provide for managing TUTORINGEZ’s social sharing to control what information you make available through TUTORINGEZ’s social features.

 

6.        Children's Privacy 

 

We do not knowingly collect personal information online from children under the age of 13.

If you’re a parent or guardian and you believe we have collected your child’s information, please contact us at customerservice@tutoringez.com.

 

7.        Protection of Personal Information

 

We use a variety of technical, administrative, and organizational security measures, including encryption and authentication tools in certain circumstances, that are intended to protect your personal information. Please be aware that despite our efforts, no data security measures can guarantee security. You can help keep your data safe by taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

 

8.        Retention of Personal Information

 

We retain your personal information for as long as reasonably necessary to fulfill the purposes described in this Policy or disclosed to you at the time of collection, unless otherwise required or permitted by law. For example, we keep your account profile information for as long as you keep your TUTORINGEZ account, but we may keep your purchase history longer to comply with our legal, tax, accounting and recordkeeping obligations, administer applicable returns and warranty programs, and for research, development and safety purposes, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims or comply with legal obligations. 

 

9.        Managing Your Privacy Rights and Choices

 

Privacy Rights. 

You may have certain rights identified below under applicable laws of where you reside with respect to your personal information. We have full discretion in choosing to voluntarily provide you with some or all of those rights regardless of the state in which you reside..

Depending upon the applicable law, access to your rights may be denied, such as: (a) when denial is required or permitted by law; (b) when granting access would have a negative impact on another's privacy; or (c) to protect our rights and properties.

The privacy rights you may have include the following:

• Right to know and access your personal information. You may have the right to know what personal information we collect about you, including the categories of personal information, the sources from and purposes for which we collect it, and the types of recipients we disclose it to, and to request a copy of the specific pieces of personal information that we maintain about you.

• Right to correct your personal information. Right to correct inaccurate personal information that we maintain about you.

• Right to delete your personal information. You may request the deletion of their personal information that we have collected about you, subject to certain exceptions.

• Right to opt out of “sales” or “sharing” for cross-context behavioral advertising or targeted advertising. You may request to opt-out of our sale of your personal information and sharing of their personal information for cross context behavioral advertising or targeted advertising. We share your personal information with third parties (such as marketing and advertising networks and social platforms) for behavioral advertising or disclose your personal information to other third-party partners in accordance with your privacy settings and/or consent. These types of disclosures of your personal information may be deemed a “sale” or “sharing” of your personal information under applicable privacy laws.

• Right to non-discrimination. You have the rightnot to be subject to discriminatory treatment for exercising your rights under certain laws.

 

Exercising your Rights and Choices.

You may submit privacy rights requests and manage your privacy choices in several ways.

Submitting Privacy Rights Requests. 

You may request to access your personal information (both the categories of data we collect, which is laid out in this policy, and specific pieces of information), obtain an electronic copy of your personal information, correct your personal information if it is incomplete or inaccurate, or delete or restrict sharing of your personal information in certain circumstances, as provided by applicable law.

• Non-Discrimination. We will not discriminate against you for making these requests. If you request to delete your account, you can create a new account on our Platform at any time.

• Verification. We will verify your request either through a message sent to the email address associated with your account (so you must have access to this email account) or by asking you to provide information matching what we have for you within our systems. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.

• Authorized Agents. You or your authorized agent may request to exercise your rights. Before we can act on a request from your authorized agent, we may require verification of your identity and proof from the authorized agent that they can act on your behalf. We may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

• Contacting Us. If you have a request regarding your personal information that cannot be fulfilled from your account settings, please contact us. 

• Denials and Appeals. If we deny your request, we will notify you and provide our reasons for the denial and instructions regarding the rights you may have under applicable laws to appeal the decision. If the appeal is denied, we will notify you of your rights under applicable laws to contact the Attorney General to submit a complaint.

 

Opting Out of Direct Marketing. 

If you have a TUTORINGEZ account, you can opt-out of receiving TUTORINGEZ’s email or SMS marketing via the "Communication Preferences" section in your TUTORINGEZ.com account settings. Alternatively, you can opt-out by following the opt-out or unsubscribe instructions in the message or by contacting us. 

Managing your cookie and advertising preferences.

There are several ways that you can manage your preferences for cookies and advertising by us and on our websites. You can review or change your preferences for most cookies and tags on our websites, other than those that are necessary for operation and functionality, by adjusting your cookie settings in your browser. These preferences are browser and device-specific, so you will need to set your preferences for each browser and device you use, and if you subsequently delete or block cookies, you may need to reapply these settings. 

 

Opt-out of Targeted Advertising.  

We share your personal information with third parties (such as marketing and advertising networks and social platforms) for targeted advertising. These types of disclosures of your personal information may be deemed a “sale” or “sharing” of your personal information under applicable privacy laws.  However, TUTORINGEZ does not disclose, sell, share, or rent your personal information for money or compensation.  

You may opt out of targeted advertising by clicking “Your Privacy Choices” in the footer of our website or by accessing the Privacy & Cookies page. Your choice is linked to your privacy preferences in your Member account’s Privacy & Cookies page.  Opting-out of sharing for targeted advertising will also opt you out of all advertising settings in your Privacy & Cookies page. Note, you can opt-in to targeted advertising again by either: (a) enabling targeted advertising through the “Your Privacy Choices” page; or (b) enabling “Behavioral Advertising” or “Profile-Based Advertising” through the Privacy & Cookies page. If you opt-in again, your personal information will be shared with third-party partners for targeted advertising purposes.  If you opt-out as a guest, your preferences will only apply to the device or browser where you made the selection.  To have your preferences apply across all TUTORINGEZ apps and devices, sign-in to make your selection. You can also opt-out by emailing us at customerservice@tutoringez.com.  

 

Update Your Profile Information. 

You can update certain personal information, like your email, address, and phone number, by logging in and updating it through your TUTORINGEZ Member account settings.

Managing the content you post. 

You can request removal of content you have posted on the Platform, but please note that removal may not encompass all possible locations, for example, back-ups or sharing by other users initiated prior to removal. 

 

Manage Profile Visibility.

You can adjust how others may view your profile and account information and interact with you on the Platform by logging into your TUTORINGEZ account and adjusting your profile visibility settings.

Additional tools to manage what data we collect.

When using our Platform, we also provide in time notice or obtain consent for certain practices. For example, we will obtain consent to use your location or to send push notifications. We may obtain this consent through the Platform or using the standard permissions available on your device. Your web browser or mobile device platform may also provide additional tools to allow you to control when your device collects or shares certain categories of personal information. For example, your mobile device or web browser may offer tools to allow you to manage cookie usage or location sharing. We encourage you to familiarize yourself with and use the tools available on your device.

 

10.    About Cookies and Similar Technologies

 

TUTORINGEZ, our service providers and third parties collect information, which may include personal information, from your browser, devices, or apps when you use our Platform using a variety of methods, such as cookies, pixel tags, identifiers for mobile devices, and other similar technologies. The information collected by these cookies and similar technologies may include your: IP address; unique cookie identifier and information obtained through cookies; unique device identifier and device type; domain, browser type and language, operating system, and system settings; country and time zone; previously visited websites; information about your interaction with our Platform such as click behavior, purchases and indicated preferences; and access times and referring URLs.

We use cookies and similar technologies to analyze and understand how you access, use, and interact with our Platform and our consumer’s preferences (such as country and language choices), as well as to assess, secure, protect, optimize, and improve the performance of our Platform. This enables us to provide services to our consumers and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about Platform traffic and interaction, to conduct analytics, identify trends and obtain statistics so that we can improve our Platform. We also use cookies and similar technologies to target advertising and content across our Platform and third-party sites and services.

 

Third-Party Technologies and Services.

Some of the cookies and similar technologies we use are operated by third party companies. We use third-party services, such as Google Analytics and its advertising products, such as Google Signals and Google Ads, that may collect usage data (using cookies, pixel tags and similar tools) about our Platform to provide us with reports and metrics that help us to evaluate usage of our Platform, improve performance and user experiences, and serve relevant advertising to you. We also use third-party technologies and services, such as reCAPTCHA, to support the security of our Platform and protect against fraud and abuse.  In some cases, the processing of this data is subject to these third parties’ privacy policies (for example, for Google Analytics, see Google’s Privacy & Terms and for reCAPTCHA see Google’s Privacy Policy). 

You may see our ads on other websites, such as our partner’s websites, because we use third-party ad services. Through these ad services, we can show you ads that may be tailored to your individual interests. These ad services may also track your online activities over time and across multiple websites and apps by collecting information through automated means. This data collection takes place both on our Platform and on third-party websites and apps that participate in these ad services.

 

Managing Your Cookie Preferences.

We make available several ways for you to manage your cookies within our Platform. Many of these are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Platform; in addition, if you delete or block cookies, you may need to reapply these preferences. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or contextual ads from us. 

Mobile settings.

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Some of our apps may include third-party advertising. You can adjust your advertising preferences on your mobile device at the device level. For example, turn off new app tracking requests, adjust your tracking preferences in iOS, visit Settings > Privacy & Security > Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads.

Industry ad choice programs.

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You can also control how participating third-party ad companies use the information that they collect about your visits to our sites and your use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices tool to help control interest-based advertising on apps on your mobile device.  Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or ‘contextual’ ads on our Platform. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

Browser settings.

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For a comprehensive and up-to-date summary of every third-party accessing your web browser (through TUTORINGEZ Platform or otherwise), we recommend installing a web browser plugin built for this purpose. Your browser may offer choices to manage your cookies, including blocking all or third-party cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser “Help” menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Platform more efficient and some of our services will not function properly.

 

Do Not Track. 

Please note that we do not recognize or respond to any signal which your browser might transmit through the “Do Not Track” feature your browser might have. If you wish to disable cookies on our Platform, you should not rely on any “Do Not Track” feature your browser might have.

 

11.        Using the TUTORINGEZ Platform with Third-Party Products and Services

 

Our Platform allows you to interact with a wide variety of other digital products and services. For example, our Platform can integrate with third-party devices for activity tracking, social networks, music streaming services and other digital services. 

If you choose to connect your TUTORINGEZ account with a third-party device or account, your privacy rights on third-party platforms will be governed by their respective policies. For example, if you choose to share your TUTORINGEZ activity on third-party social media platforms, the policies of those platforms govern the data that resides there. 

Our Platform may provide links to other third-party websites and apps for your convenience or information. Linked sites and apps have their own privacy notices or policies, which we strongly encourage you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.

 

12.        Changes to Our Privacy Policy

 

Applicable law and our practices change over time. If we decide to update our Privacy Policy, we will post the changes on our Platform. If we materially change the way in which we process your personal information, we will provide you with prior notice, including via email to the address we have on file, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our Privacy Policy and keep yourself informed of our practices.

 

13.        Questions, Feedback and Metrics

 

We welcome questions, comments and concerns about our privacy policy and privacy practices. If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your personal information, please use our contact messaging system. 

 

14.      Additional State-Specific Information

 

Information for California Residents

This section provides California residents with additional information regarding our collection, use and disclosure of their personal information that supplements the disclosures in our Privacy Policy above. This section uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations.

 

Categories of Personal Information Collected.

We collect the personal information detailed in the “Personal Information We Collect” section above. This information includes the following categories of personal information as defined under California law:

• Identifiers

• Personal Information described in California Section 1798.80(e)

• Characteristics of protected classifications under California or federal law

• Commercial Information

• Internet or other electronic activity information

• Geolocation data

• Audio, electronic, visual, thermal, olfactory, or similar information

• Inferences

• Sensitive personal information, specifically: (a) log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, (b) precise geolocation information; and (c) personal information collected and analyzed concerning a consumer’s health.

Categories of Personal Information Disclosed for Business Purposes.

The personal information we process varies based upon our relationship and interactions with you. We may disclose the categories of personal information described above for the business purposes outlined in “How and Why We Use Personal Information”. The recipients to whom we may disclose your personal information (and that may have received such information during the last 12-months) for business purposes include: our affiliates and subsidiaries; order processing, fulfillment, shipping, and logistics vendors; payment processors and financial institutions; analytics and research vendors; information technology vendors; fraud prevention and security vendors; vendors supporting legal, compliance, accounting, audits and other internal functions; and certain marketing and advertising vendors.

Categories of Personal Information Shared with Third Parties. 

We share your personal information with third parties (such as marketing and advertising networks and social platforms) for behavioral advertising or with other third-party partners in accordance with your privacy settings and/or consent. These types of disclosures of your personal information may be deemed a “sale” or “sharing” of your personal information under California privacy laws.  California privacy laws define a “sale” as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising or with affiliates and business partners. TUTORINGEZ does not disclose, sell, share, or rent your personal information to third parties in exchange for money or compensation. Further, we do not “sell” or “share” sensitive personal information, nor do we “sell” or “share” any personal information about individuals who we know are under the age of 16.  Below is an overview of the categories of third parties with whom we share your information and the categories of personal information they receive:

 

Categories of Third Parties

Categories of Personal Information

Advertising and Social Platforms and Networks

• Identifiers

• Device information

• Online Activity and Browsing Information

• Inferences

Third Party Partners Connected to Your Membership (in accordance with your privacy settings and/or your consent)

• Identifiers

• Commercial Information

• Inferences

  

Privacy Rights. 

California residents have the following rights with respect to their personal information:

• To know what personal information is collected

• To access personal information

• To correct personal information

• To delete personal information

• To opt-out of the “sale” of personal information

• To opt-out of “sharing” of personal information for cross-context behavioral advertising

• To limit the use of sensitive personal information

• To non-discrimination

 

Notice of Financial Incentive Programs. 

We offer consumers the ability to become a TUTORINGEZ Member, which provides certain perks, rewards, and exclusive offers. We may also provide consumers with price discounts and coupons, as well as access to programs, such as sweepstakes, contest, or other similar promotional campaigns. These programs may be considered “financial incentives” programs under California law. 

When you sign up for one of these programs, we may ask you to provide your contact details (such as email address and/or phone number), collect information about your activities on our Platform and your purchases, and draw inferences about your preferences, and collect other categories of personal information about you. The value of your personal information to us is reasonably related to the value of the perks, rewards, exclusive offers and discounts, or other benefits that are provided as part of the applicable program. We estimate the value of personal information by considering factors, including but not limited to, expenses related to the collection, storage, and retention of personal information in the context of the program and the expenses related to the administration of the program. The overall value of personal information to us is depends on what offerings you take advantage of and whether you opt-out of any offerings.

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Your participation in any financial incentive program is optional, and you may withdraw from the program at any time:

• For marketing-based incentives, you may unsubscribe by following the instructions in the communication.

• For membership-based incentives, you may delete your account through your account settings, by submitting a request through our TUTORINGEZ Contact Webform.

 

Shine the Light. 

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, call us at 1.800.806.6453 or email us at privacy@tutoringez.com, and include in your request a current California address and your attestation that you are a California resident. 

  

Information for Virginia Residents

This section provides Virginia residents with additional information regarding our collection, use and disclosure of their personal information that supplements the disclosures in our Privacy Policy above. This section uses certain terms that have the meaning given to them in the Virginia Consumer Data Protection Act.

Personal Information Processed for Targeted Advertising.

We process and disclose the following categories of personal information for targeted advertising:  identifiers, device information, online activity and browsing information, and inferences.  We share each of these categories of personal information Advertising and Social Platforms and Networks.

Privacy Rights.

Virginia residents have the following rights with respect to their personal information:

• To access personal information

• To correct personal information

• To delete personal information

• To opt out of targeted advertising

• To non-discrimination

• To appeal