Tutorac Privacy Policy

Electronic Acceptance/Clickwrap

You agree that by clicking a simple button to accept the Agreement you agree to all the terms and conditions. you understand that under the U.S. federal Electronic Signatures in Global and National Commerce Act (“ESIGN”), clickwrap agreements, such as this Agreement that simply requires you to click a box to accept its terms, holds the same status as “wet ink” signatures. The signing of this Agreement by clicking the box, signifies your acceptance of the terms and conditions as specified herein. It also signifies that you are over eighteen (18) years of age and have the authority to enter into such this Agreement. If you are under eighteen (18) years of age, you can only become a Registrant through the permission of your parent or guardian who will be the Registrant and agree to monitor your usage.

By using our Website, you acknowledge that you have read and understand all of this Privacy Policy, and you agree to be bound by our Privacy Policy. We are sensitive to the concerns that you have about the use of the information that you disclose to us via our Website. Accordingly, this Privacy Policy sets forth our privacy practices and the possible uses of the information that we gather via our Website.

As a Registrant, you specifically agree to this Privacy Policy, as well as our Terms of Use. You agree and accept this Privacy Policy and our Terms of Use, all of which forms a binding agreement (“Agreement”) between you and us. If you do not agree to this Privacy Policy, you agree that you will not use our Website. The Company reserves the right to change this Privacy Policy at any time and will post such changes via our Website. If you do not agree to the amended Privacy Policy, you agree to stop using our Website. You will be deemed to have accepted the amended Privacy Policy if you continue to use our Website after such changes have been made showing the “Last Updated” date. Any changes will be effective immediately upon the posting the new date. If changes are made, we will notify you by stating the date the Privacy Policy was last modified. Your continued use of our Websiteafter the effective date of a revised version of this Agreement constitutes your acceptance of ourrevised Privacy Policy.

We have established this Privacy Policy to let Registrants know the kinds of information we may gather from our Website, how and why we gather the information, what we use the information for, and when we might disclose the information.

Please be advised that the practices described in this Privacy Policy apply only to information gathered by us and any PII we may also receive about Registrants from other online and offline sources, such as public databases, in connection with our Website. Each Registrant that downloads or usesour Website agrees to have their information processed in accordance with this Privacy Policy.

Definitions

Any capitalized words not defined in this Privacy Policy shall have the meaning ascribed to them in the Terms of Use.

Acceptance of This Privacy Policy

By using our Website and our Products / Services each Registrant accepts the terms set forth in this Privacy Policy. Anyone that does not agree to the terms of this Privacy Policy agrees that they shall not use our Website, Products or Services. The only recourse for Registrants that do not agree to the terms of this Privacy Policy shall be to discontinue using our Website, Products, and Services. By using our Website, Products, or Services, you consent to having your personal data transferred to and processed by us, our consultants and our service providers.

Consent

By using our Website, Products and/or Services each Registrant consents to our Privacy Policy, as well as the limitation of liability, arbitration, refund policy and our Terms of Use.

Changes to This Privacy Policy

We reserve the right to revise or amend the terms of our Privacy Policy at any time without prior notice and each Registrant agrees that the revisions or amendments will be effective upon updating on this Website. We agree to change the “Last Updated” date appearing at the top of this page to reflect each time we make any changes, and it is the responsibility of each Registrant to check back often. Continued use of our Website, Products, and Services following the posting of changes shall mean that youaccept those changes.

Our Privacy P​olicy and Terms of Use form the Agreement with each Registrant and sets out the basis on which any personal data we collect from them, or that they provide to us, will be utilized by u​s. Any Content or data we collect will only be used in accordance with this P​rivacy Policy and the Terms of Use. Please read the following carefully to understand o​ur views and practices regarding Content, personally identifiable information (“PII”), and data and how it​ will be treated.

Through the use of our ​Website, Products or Services each Registrant agrees to the terms provided in our​ Privacy Policy regarding the use of their personal Content, PII, and data that we collect. Registrants that feel our Privacy Policy is unacceptable to them agree and represent that their only recourse is to discontinue use of our Website and discontinue use of ourProducts and Services.

Communications From Us

To improve our Services, we may ask Registrants to complete surveys that we use for research purposes, although Registrants do not have to mandatorily respond to them. We may periodically send Registrants information regarding our Website, updates, promotional emails, special offers, or other information which we think Registrants may find interesting. In such cases we will use the email address you provided to us and which you agree we may send emails to for such purposes. We will also use your PII to respond to requests you may make of us. We may also refer to your PII to better understand your needs and how we can improve our Website. You may opt-out of receiving promotional materials by following the opt-out instructions contained in the materials or by emailing Company at support@tutorac.com

Information We May Collect From Registrants

Each Registrant agrees that by entering their PII via our Website or otherwise providing their PII to us, we may collect the following information about them and use it in providing the Services associated with our Website: Name, contact information, including email address, phone number, age, gender, IP (Internet Protocol) address, your Registrant handle or Registrant name, geographic location, geo positional data, information supplied during the processing of registering with us, data usage trends, data showing the effectiveness of promotional campaigns, browser information, demographic information, browsing preferences, browsing data, the type of device being used, Website usage information, information regarding any URLs used with our Website, data regarding use of our Website, other information relevant to surveys and/or offers, and any other information we are legally allowed to collect or is required for us to collect to have appropriate operations of our platform. We require this information to provide Registrants with better Products and Services and support.

Automatically Collected Information

Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Site, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features on our Website are visited and by how many people. Cookies and similar tracking technologies, such as beacons, scripts, web beacons and tags (which together we refer to as “cookies”), are small bits of text, usually stored on a user's computer hard drive or within a browser. They enable a website to remember information about the user's visit to the website. On mobile websites and mobile applications, we use device IDs and/or Advertising IDs in a similar manner to which we use cookies. You can find more information about cookies at: www.allaboutcookies.org or www.youronlinechoices.eu.

The types of cookies we may use include but are not limited to

• Session Cookies: These are cookies which expire once you close your web browser.
• Persistent Cookies: These are cookies which stay on your desktop or mobile device for a specific period of time or until you delete them from your device.
• First-party cookies: These are cookies that are set by the website that you are visiting at that time, in this case Tutorac, or by a third party at Tutorac’s request.
• Third-party cookies: These are cookies that are set by a third-party other than that of the website you are visiting. If you visit our Website and another party sets a cookie through that website this would be considered a third-party cookie.
• Essential cookies: These are sometimes called “strictly necessary” because without the use of this type of cookie we cannot provide many of the services that you need to use our Website. They are usually only set in response to actions made by you related to a request for Services or to use various features on our Website. For example, essential cookies help remember your preferences, such as setting your privacy preference or logging in, as you move around our Website and use its features.
• Analytical cookies: These are, as the name implies, used to analyze and track information about your website visits so we can review performance and use that information to better improve our Website, its features, Products, Services, and Content. The information these cookies collect is aggregated and therefore anonymous.
• Functionality or Preference cookies: These let us operate various features on our Website according to your preferences. These cookies help us to provide you with our Services based on information you provide to us, such as your username, your preferred language choice, and how you have customized our Website features. These preferences are recalled and the next time you visit ourWebsite you won’t have to set them again. They may be set by us or by third party providers whose services we have added to our pages and they help the Website functional properly according to your preferences.
• Targeting or Marketing cookies: These are cookies that are placed by third-party advertising platforms or networks in order to deliver ads and track ad performance, enabling advertising networks to deliver ads that may be relevant to you based upon your activities. This is known as behavioral, tracking, or targeted advertising on a social media platform or website. The information is then used to show you advertisements that you may be interested when you visit other websites or social media platforms. For example, these cookies remember which browsers have visited the website. If you do not allow these cookies you will still see basic advertising on your browser but that advertising will be general in nature and not specific to your interests.

You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. Please refer to your devices settings to make those changes.

We may receive confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our Website, Products, and Services.

We may use this data to customize Content for you that we think you might like, based on your usage patterns. We may also use it to improve the Website – for example, this data can tell us how often users use a particular feature, Product, or Service offered though our Website, and we can use that knowledge to make improvements.

Use of Cookies

Our Website uses cookies. A cookie is a small file which asks permission to be placed on a computer's hard drive. Once someone has accepted the cookie, the file is added and the cookie helps analyze web traffic and browsing habits, such as what areas of our Website are visited most frequently. At times we may gather information through the use of a cookie file which enables us to gather statistical information regarding the use of our Website. This helps us to improve not only our Website, but the Products and Services we can provide to Registrants. We may use analytical software to track Registrant habits and trends.

Registrants do have the choice to decline cookies. Most web browsers automatically accept cookies, but people can usually modify their browser setting to decline cookies if they prefer. Should you choose to decline cookies you may be unable to access certain information or parts of our Website, and some or all of the Services may not work properly. Our advertisers and promoters or third party tool integration services may also use cookies, over which we have no control.

We may use cookies to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you register with our Website, a cookie helps us recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, preferences, and so on. When you return to our Website, the information you previously provided can be retrieved, so you can easily use the Website features that you may have customized.

We may also collect anonymous and aggregate information from you about your preferences in navigating the Website by using cookies, action tags and other methods. Cookies are small text files that identify your computer. We may use cookies to, among other things, monitor usage of the Website, customize features of the Website, identify your computer operating system and browser, and complete transactions. An action tag is a small, graphic image on a webpage that is designed to allow the website owner or a third party to monitor who is visiting a website by collecting the IP address of the computer to which the tag is sent, the URL of the webpage that the tag comes from and the time at which such webpage was viewed. Action tags may be associated with cookie information. We may also use such anonymous and aggregate information for promotional and other business purposes.

IP Address

An IP (Internet protocol) Address is automatically assigned to the computer that someone is using by their Internet Service Provider (ISP) and is identified and logged automatically in our server log files whenever someone visits our Website or uses our Products or Services. This also allows us to identify the time(s) of visit(s) and the page(s) of our Websitethat have been visited. Our collecting IP Addresses is considered a standard practice on the Internet and is done by many third party sites.

Location Information

We may also obtain information about a Registrant’s physical location, such as by use of a global positioning system (“GPS”) and other geolocation features in your computer, laptop, or mobile device, or from other information we collect. For example, a Registrant’s IP Address indicates the general geographic region from which they are connecting to the Internet.

Much of the information we obtain is from your electronic device and includes but is not limited to:

• Device operations: information about the activities performed on your device, such as windows open while using our Website, or mouse movements.
• Device attributes: information such as the operating system your device uses, hardware and software versions, battery level, signal strength, available storage space, browser type, application and file names and types, and device plugins.
• Identifiers: unique identifiers, device IDs, and other identifiers that may be available from games, apps or accounts you use, and family device IDs (or other identifiers unique to ourProducts and Services associated with the same device or account).
• Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
• Data from device settings: information you allow us to receive through your electronic device settings that you turn on, such as access to your global positioning system (“GPS”) location, camera or photos. If you decide not to turn on your GPS location function in your deviceyoumay not be able to use any or all the features onour Website.
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or that operate on your network.
• Cookie data: data from cookies stored on your device, including cookie IDs and settings.
• Server Logs: We are having database logs for each query which is firing through front end or mobile application along with exception logs.
• Cookies: We are storing a Registrant’s basic information like name, email address, role, mobile number inside cookies along with a secured user token (JWT).
• Tracking Tools: We are using Facebook pixel tracking, google tag manager, and other required tracking tools to track a user’s journey in our Website application.

Heat Map and Tracking Software

We may use various types of website tracking software (“Tracking Software”) to track mouse movement, scrolling, and clicks on our Website in order to better understand ourRegistrants’needs and to optimize the use of our Products and Services. The most common form of Tracking Software is referred to as a “heat map” and the forms of heat maps include scroll maps, click maps, and movement maps. Heat maps are graphical representations of data where values are depicted by color. You specifically agree to our use of Tracking Software and heat maps.

Our Tracking Software may capture screen shots of a Registrant’s mouse movements, scrolling, and clicking habits which helps us understand what Registrants want, care about, and do on our Website by visually representing their clicks, taps and scrolling behavior. Some of the reasons why we use heat map software are as follows: to see if Registrants are reaching important Content or failing to see it, to find and use a page’s main links, buttons, opt-ins, and CTAs, to see if Registrants are getting distracted by non-clickable elements, and to compare usage against mobile, tablet and desktop devices.

We use Tracking Software to help us better understand our Registrants’ experience (e.g. how much time they spend on which pages, which links they choose to click, what Registrants do and don’t like, etc.) and this enables us to build and maintain our Products and Services with Registrant feedback. This Tracking Software uses cookies and other technologies to collect data on our Registrants’ behavior and their devices. This includes a device's IP address (processed during your Website visit or use of our Products and Services and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location, and the preferred language used to display our Website. This Tracking Software stores this information on our behalf in a pseudonymized Registrant profile.

We may use social media pixels to track and collect general information about your use in compliance with different social media sites (Facebook, Twitter, etc.) for the purpose of promoting products, tracking conversions, remarketing, running target advertisements and so forth.

Third parties like Facebook may use their own cookies, web beacons and other technologies to collect and receive information from our Website for the purpose of providing target advertisements. You may see our ads on Facebook, other social media platforms, and other third party websites after you have visited our Website.

Website Analytics

We use multiple web analytics tools provided by service partners such as Google Analytics, may be used to collect information about how you interact with our Website and software, including what pages you visit, what site you visited prior to visiting our Website, how much time you spend on each page, what operating system and web browser you use and network and IP information. We use the information provided by these tools to improve our Products and Services. These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our Website or use our Products or Services. Each cookie cannot be used by anyone other than the service provider (example: Google for Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside, or may be stored by our servers to analyze the usage behavior. The information collected is used and shared by these service providers in accordance with their individual privacy policies. You can control the technologies we use by utilizing settings in your browser or third-party tools.You can opt-out of making your activity available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

We are using following 3rd party tools in our platform, including but not limited to

• MarvinJS: Representation Tool used in text editors.
• Draw.IO: Drawing Tool used in text editors.
• MathJx: For displaying formulas.
• Affinda: Resume Parser in user profile and onboarding.
• Chime: Video conferencing and live training tool.
• Video JS: Used to play transcoded videos and used in video courses and live meetings recordings.
• AWS S3 Bucket: For storing all Images, videos, documents and other assets.
• AWS EC2: As computing unit.
• AWS RDS: As database management system.
• AWS cloudfront: As CDN.
• AWS media convert pipeline: For transcoding video files.
• Payment Gateway: PayPal, RazorPay, Stripe, or other gateway we may choose.
• Google tag manager: For analytics.
• Freshdesk: For creating tickets of various support requirements.

How we are securing the PII and Financial Information of any Registrant (credit card details, mobile number, email address, any other id number, and the documents for verification) and where we are storing it?

• We are storing only required information of cards like last 4 digit of cards, card owner name, card token for payment gateway.
• We are storing mobile number and email address in our database which is secured with Amazon RDS.
• We are storing PII of each Visitor and Registrant in our database but while serving through frontend application we are encrypting the same to make our application secure.
• We are storing all documents (like photographs and government recognized identification) on S3 Bucket and serving them through cloudfront to provide the type of speed and security that is typically used in the industry.
• For video course content we are transcoding the video files and serve it to the learners using encrypted signed URL via cloudfront.
• The above points shares a reference for the users; however, there might be places or circumstances wherein we have changed few tools or locations or storage areas to provide better security.

The technical security driven aspects for our platform are as follows

• Data Encryption: Use HTTPS to encrypt data in transit. Employ SSL/TLS certificates to ensure secure communication between the user's browser and the server.
• Authentication and Authorization: User authentication is secured using secure JWT tokens and users access is restricted by authorization of different modules based on their roles and permissions.
• Data Protection: All data is transmitted via a secure channel. All video course data is transcoded to S3 bucket and then served to Registrants as a signed URL via cloudfront. Other assets coming from S3 are also transmitted in the same fashion.
• Cross-Site Scripting (XSS) Prevention: Input validation and output encoding added to prevent XSS attacks, which can inject malicious scripts into your web pages.
• SQL Injection Prevention: Used parameterized queries and ORM to prevent SQL injection attacks when interacting with databases.
• API Security: APIs security with proper authentication and authorization mechanisms. Implementation of rate limiting and throttling to prevent abuse of your APIs.
• Error Handling: Error handling to avoid exposing sensitive information in error messages.
• Code Reviews and Security Audits: Regular code reviews to identify and fix security vulnerabilities.
• Backup and Disaster Recovery: Used AWS RDS auto backup services for backing up data on regular intervals.

Work Diaries and Work View

1.Gathering Tutor Data: We periodically collect information about a Tutor’s professional engagements, including data obtained automatically. This information forms part of what we refer to as the Tutor's Teaching History.

2.Teaching History: The Teaching History feature comprises details provided by Tutors, such as educational background, memos, and other relevant work-related information. It also includes certain data automatically collected during project work, which may involve Personally Identifiable Information (PII).

3.Sharing with Registrants: The information within a Tutor’s Teaching History may be shared with all registered users on our platform. This sharing also aims to enhance learners' understanding of our Tutors and facilitate informed choices.

4.Data Usage for Improvement and Analysis: We reserve the right to use de-identified or aggregated data from Teaching Histories for statistical analysis, as well as for developing, marketing, and researching our Products and Services.

Third-Party Analytics Providers, Ad Servers and Similar Third Parties

advertising agencies and vendors who use technology to help us understand how people use our Website, Products, and Services. These vendors may use technologies to serve you advertisements that may interest you, but if you prefer, you can opt out of receiving these advertisements. We may work with various social media platforms, ad networks, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on our Website platform, including pages viewed and the actions taken when visiting; to serve our advertisements on other websites, social media platforms, within mobile apps, and elsewhere online. This helps us obtain information regarding the use of our Website and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on our Website, as well as third party websites or services. Some of these parties may collect PII when you visit our Website or other online websites and services. If you wish to opt out of interest-based advertising from participating companies, please contact us at support@tutorac.com. You must opt out on each device and each browser where you want your choice to apply. If you choose to opt out, please note you will continue to receive advertisements, but they may be less relevant to you.

Do Not Track Signals and GPC

Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. We do not generally alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Global Privacy Control (GPC) is a technical specification that you can use to inform websites of your privacy preferences regarding ad trackers. If you do choose to set up GPC, it may impact the functionality of the Site, but we honor the GPC signal automatically in your cookie preferences.

Messaging

Tutors and Learners may communicate with each other through our Website. We have no control over what is said or communicated and reserve the right to cancel a Registrant’s account if such communications are demeaning, derogatory, hateful, condescending, or hateful, which we shall determine in our sole and absolute discretion.

Communications Between Registrants or Others

You understand and agree that we are not responsible or liable for any loss, damages or costs associated in any way with communications, activities or interactions you may have with others, including but not limited to Registrants, either on our website platform or outside our website platform. Any communications, activities or interactions you may have with others, either on our website platform or outside our website platform, are completely at your sole risk.

Targeted Advertisements

Targeted ads or interest-based offers may be presented to you based on your activities on our Website, our Website, other third party sites, and based on the products or services you currently own. These offers will display as varying product banners presented to you. we also partner with third parties to manage our advertising on our Website and third party sites. Our third party partners may use technologies such as cookies to gather information about such activities in order to provide you with advertising based upon your browsing activities and interests, and to measure advertising effectiveness. If you are in the US or Canada and wish to opt out of interest-based advertising visit http://preferences-mgr.truste.com. If you are located in the European Union, please visit www.youronlinechoices.eu. Please note you will continue to receive generic ads. While we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. Please visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You can also visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program.

What we Do With the Information we Gather

Each Registrant agrees that wemay use the information we gather as follows: In order to process a Registrant’s purchase of our Products or Services, we must share certain PII every time a Registrant signs up for our Products or Services. Such information may include the Registrant’s e-mail address, physical address, phone number, and credit card information. Our service representatives may use your telephone number or e-mail address to notify you of the status of your account as necessary and appropriate. We may share Registrant information with vendors, business clients, and other third-party providers who are performing services for us. We may also use Registrant information for internal record keeping and data analysis. For our statistical purposes, we gather details of Registrant visits to our Websiteand the information that Registrants access, including, but not limited to, traffic data, location data, browser usage, page visits, weblogs, and other communication data. When Registrants contact us, we may keep a record of that correspondence. We also use Registrants Information to ensure that Content from our Website is presented in the most effective manner for computer or mobile devices.

We reserve the right to share your Information in response to duly authorized information requests of governmental authorities or where required by law. We may also disclose your PII if necessary for fraud protection and credit risk reduction purposes, or in the good-faith belief that such action is necessary to protect and defend the rights or property of the Company or the Registrants of our Website or to act under urgent circumstances to protect the safety of the Company, its employees, other Registrants of our Website, our service providers, advertisers, or members of the public.

From time to time, personal financial information (including credit card information) may be transmitted to facilitate transactions with us between Registrants who are purchasing our Products or Services. We will not share such personal financial information with third parties other than those third parties such as banks, CPAs, auditors, attorneys, and consultants, processing gateways and merchant processors required to process a Registrant’s purchase, and Registrants understand that we cannot control how the banks, processing gateways or merchant processors will use such personal financial information. Therefore, Registrants using this Website and the Services hereby consent to such sharing of personal financial information. Each Registrant agrees to assume the risk and agrees that it is their responsibility to properly handle, secure, not store and destroy such personal financial information as may be necessary to protect it from misuse. You agree that we shall not be liable to Registrants or any third party for misuse of such Content, PII, or personal financial information.

We may disclose information we collect from Registrants to an affiliate or other third party in the event of any merger, sale, joint venture, assignment, reorganization, liquidation, transfer or other disposition of all or any portion of our business, assets, or stock.

We may use third-party advertising companies to serve ads when Registrants visit our Website. These third-party advertising companies may use advertising technologies such as cookies, web beacons and other similar advertising technologies. These companies may use aggregated information about your visits to our Website, third party sites, and use of our Products and Services in order to provide advertisements and promotions about ourProducts and Services that we believe Registrants may find of interest.

We may also release Registrants information when we believe release is appropriate to comply with the law, enforce our Website policies and Terms of Use, or protect ours or other’s rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for data analysis, improving our Products and Services, marketing, promotional, advertising, or other uses.

From time to time, personal and business financial information (“Financial Information”) (including, but not limited to, banking information, credit card information, payment facilitator details, or other financial information) may be transmitted to facilitate transactions between you and us. We will never share such Financial Information with third parties other than those third parties such as payment facilitators, banks, processing gateways, financial intermediaries, and merchant processors required to process and facilitate the sending and receiving of payments, and you understand that we cannot control how these third parties will use such Financial Information to perform their services to facilitate payments. Therefore, you hereby consent to such sharing of Financial Information. You agree to assume the risk and agree that it is your responsibility to properly handle, secure, not store and destroy such Financial Information as may be necessary to protect it from misuse. You hereby consent to such sharing of Financial Information and hold us harmless and indemnify us from any claims, breaches, loss, or damage resulting from the use of those payment facilitators, banks, processing gateways, financial intermediaries, and merchant processors we use. You agree we shall not be liable to you or any third party for misuse of such Financial Information.

Under what other circumstances may we release PII?

In addition to sharing your PII with third parties as described above, we may also release your PII to other third parties if we believe that such release is necessary (a) to comply with the law (e.g., a legal process or a statutory authorization or requirement) or a court order, (b) in order to apply or enforce the Terms of Use, (c) to protect you, other Website users, or us from fraudulent, abusive, or unlawful use of the Website, or (d) if we reasonably believe that a danger to any person or property requires the disclosure of such PII or otherwise if we believe such a disclosure is needed to protect our interests (as determined by us in our sole discretion).

Our rights under this Privacy Policy may be automatically assigned by us, in our sole discretion, to a third party or parties, and such an assignment will inure to the benefit of our successors, assigns and/or licensees. Without limitation of the foregoing, we may sell, transfer or otherwise share some or all of our assets, including without limitation your PII, with any company under our common control, joint venture, as well as to a potential acquirer and/or an acquirer (including without limitation in connection with a merger, reorganization, or sale of assets or stock, or in the event of bankruptcy). In each such instance, the PII we have collected from you may be one of the assets transferred in connection with such a transaction.

Online eCommerce Platform

We may use an online e-commerce platform that allows us to provide our Products and Services to you. Your information, including PII, may be transmitted through, and stored on third-party servers. By using ourProducts and Services, you consent to our collection, disclosure, storage, and use of your PII in accordance with this Privacy Policy and our Terms of Service.

Social Media, Posts, Texts, Forums and Profiles

Each Registrant agrees that we may make available through our Website, third party sites, our Website, or our Products and Services certain forms of media either now existing or to be created in the future (for example, social media, message boards, applications, chat functionality, videos, pictures, images, profile pages, text messaging and blogs) to which Registrants may be able to post Content. Please note that any Content, we, outside third parties, Visitors, or Registrants provide on these various forms of media may become public, and may be available to Visitors to our Website, third party sites, and to the general public, including without limitation the ratings and reviews that accompany any pages on our Website or third party sites. We urge Registrants to exercise discretion and good manners when disclosingany of their personal or financial information.

EACH REGISTRANT AGREES THAT WE SHALL NOT BE RESPONSIBLE FOR ANY LOSS CAUSED BY OUR USE OR THE USE BY ANY UNAUTHORIZED PERSON OR ENTITY, OF ANY CONTENT THAT REGISTRANTS DISCLOSE THROUGH OUR WEBSITE IN THE FORM OF PRODUCTS, SERVICES, TEXT, OR ANY OTHER FORM OF CONTENT.

Data Retention

Unless you request that we delete certain information (see Your Choices and Rights below), we will only retain your PII for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, as well as ongoing fraud prevention, backup, and business continuity purposes.

Information Sharing And Disclosure

We do not “sell” your PII, and we do not share your PII with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing. However, we may use third-party technologies on our Website for the purposes of advertising or marketing to you and understanding how you interact with our advertisements. This may be considered a “sale” or “sharing” of your PII for targeted advertising under applicable data protection laws. We may also share information we have collected about you, including PII, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy, or for the following business or commercial purposes:

• (a) Registrants: For Tutors who have entered into a contract with a Learner we may share their information with Learners to make the process of hiring and making payment simple. For Tutors who choose to view a request from a Learner or submit a proposal via our Website, we may share their information with the applicable Learner(s). For Tutors who have made their profiles publicly visible, we may share their information with Registrants. Note that if a Tutor is suspended from our Website platform, we may share that information with Learners for whom that Tutor has worked or submitted proposals.
• (b) Service Providers: We may hire third-party companies and individuals to facilitate the use of our Website Products and Services, and to perform various services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of Tutorac’s Products and Service features). These third party providers may include analytics companies, third-party advertising partners, payment processors, identity verification companies, security companies, or other merchants. These third parties may have access to your PII in order to perform these services to assist us.
• (c) Legal and Investigative Purposes: We will share information with government agencies as required by law including (without limitation) in response to lawful requests by public authorities to meet national security or law enforcement requirements and in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect our rights, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, or unethical, or (d) for any other purpose we determine in our sole and absolute discretion.
• (d) Internal and Business Transfers: We may share information, including PII, with a parent company, and any current or future subsidiaries or affiliates, primarily for business and operational purposes, including activities such as IT management, for them to provide services to you, or support and supplement the Products and Services we provide. We may sell, transfer, or otherwise share some or all of our assets, including your PII, in connection with a merger, acquisition, reorganization or sale of assets (including as part of the due-diligence process) or in the event of bankruptcy.
• (e) Non-Identifying Information: We may share aggregated non- identifying information and we may otherwise disclose non-identifying information (including, without limitation, hashed Information) to third parties. You agree and understand how you interact with our ads. This may be considered a “sale” or “sharing” of PII for targeted advertising under applicable data protection laws.

YOUR CHOICES AND RIGHTS

You may have certain choices and rights associated with your PII, including opting out of targeted advertising. Residents of certain locations may have the right to have an authorized agent submit requests on your behalf. You or your authorized agent may request Tutorac to honor these rights by contacting us at support@tutorac.com.

Non-Discrimination

You will not receive any discriminatory treatment from us for the exercise of your privacy rights.

Verifying Your Request

Only you, or a person that you authorize to act on your behalf, may make a request related to your PII. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected PII or a person authorized to act on your behalf. We will only use the PII that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with PII if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.

For Individuals Located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland

You have a number of rights under applicable data protection laws in relation to your PII. Under certain circumstances, you have the right to:

• Have access to your PII by submitting a request to us;
• Have your PII deleted;
• Have your PII corrected if it is wrong;
• Have the processing of your PII restricted;
• Object to further processing of your PII, including to object to marketing from us;
• Make a data portability request;
• Withdraw any consent you have provided to us;
• Restrict any automatic processing of your PII; and
• Complain to the appropriate Supervisory Authority.

To exercise any of these rights, please contact us at support@turoac.com.

Notice for California Residents

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.

California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and processing of their PII.

Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your PII over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:

• The categories of PII we have collected about you.
• The categories of sources for the PII we have collected about you.
• The specific pieces of PII we have collected about you.
• Our business or commercial purpose for collecting or “selling” your PII as defined by the CCPA.
• The categories of third parties to whom we have sold or shared your PII, if any, and the categories of PII that we have shared with each third-party recipient.

Your Right to Opt-Out of “Sale” or “Sharing” of Personal Information: California residents have the right to opt-out of the “sale” or “sharing” of their PII as defined by the CCPA by contacting us at support@tutorac.com.

Please note that we do not knowingly “sell” the PII of any individuals under the age of 18. Where we are “sharing” your PII with third parties for the purposes of cross-context behavioral advertising or profiling, you may opt-out of such sharing at any time by submitting a request to support@tutorac.com.

Your Right to Limit Use of Sensitive Personal Information: California residents may have the right to request that businesses limit the use of any sensitive PII to those uses which are necessary to perform the Services or for other specificallyenumerated business purposes under the CCPA, as amended by the CPRA. Please note that we do not use sensitive PII other than as necessary to perform the Services or as specifically permitted under the CCPA.

Your Right to Delete: California residents have the right to request that we delete any of the PII collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested PII in accordance with the CCPA, we will delete, and direct our third-party service providers to delete, your PII from their records. Your request to delete PII that we have collected may be denied if we conclude it is necessary for us to retain such PII under one or more of the exceptions listed in the CCPA.

Your Right to Correct:Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate PII we maintain about you, taking into account the nature of the PII and the purposes for which we are processing such PII. We will use commercially reasonable efforts to correct such inaccurate PII about you.

Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.

Notice for Nevada Residents

Under Nevada law, certain Nevada residents may opt out of the sale of “personally identifiable information” or PII for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” or PII includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased (or subscribed for) goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing support@turoac.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Notice for Residents of Certain Other States

The Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (CPA), and Connecticut Data Privacy Act (CTDPA) [and Utah Consumer Privacy Act (UCPA)] (“Applicable State Law”) provide residents of those states with certain rights, including the following:

Your Right to Confirm and Access: You have the right to confirm whether we are processing PII about you and access the PII we process about you.

Your Right to Portability: You have to right to obtain a copy of the PII we maintain and process about you in a portable and, to the extent technically feasible, readily-usable format.

Your Right to Delete: You have the right to request that we delete the PII we maintain or process about you.

Your Right to Correct: You have the right to request that we correct inaccuracies in the PII we maintain or process about you, taking into consideration the nature and purpose of such processing.

Your Rights to Opt-Out: You have the right to opt-out of certain types of processing of PII, including:

• Opt-Out of the “sale” of PII as defined by Applicable State Law;
• Opt-Out of targeted advertising by us;
• Opt-Out of automated profiling for the purposes of making decisions that produce legal or similarly significant effects.

Please note, as explained above, we do not “sell” PII as that word is traditionally defined. However, we do share PII with third parties to provide you with personalized advertising from us and to better understand how you interact with our Products and Services. Through the use of cookies, we may also make available certain PII to third parties for targeted advertising. You may opt-out from such targeted advertising under Applicable State Law by contacting us at legal@tutorac.com.

Appeals Process & Other Concerns

Certain information may be exempt from the rights described above under applicable law. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process. Depending on your location, you may also email legal@tutorac.com with the subject “Data Privacy Request Appeal” to provide us with details about why you are appealing the decision.

Security

We take a number of steps to protect your data, but no security is guaranteed. Tutorac takes commercially reasonable steps to help protect and secure the information it collects and stores about Tutorac’s users. We maintain reasonable administrative, technical, and physical safeguards designed to protect PII that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. However, please note that despite our efforts to protect information provided to us, we cannot guarantee that such information (including your PII) will not be lost, disclosed or accessed by accidental circumstances or by the unauthorized acts of others.

Cross-Border Data Transfers

Because we are a U.S. company, we process and store your information in the United States and our service providers may process and store it elsewhere. Tutorac may transfer your PII to a third party that is located in a jurisdiction other than the one from which we collected your PII, including to countries that have not been deemed to have an adequate level of protection for the rights and freedoms of data subjects. If we do transfer your PII to another jurisdiction, we will do so following due diligence and provided that the data recipient is subject to contractual agreements imposing obligations on it to ensure appropriate technical and organizational are implemented and maintained at all times to prevent the unauthorized and unlawful processing of PII, and the accidental loss or destruction of, or damage to, PII, consistent with our obligations under applicable data protection laws.

California Online Privacy Protection Act Compliance

As part of the California Online Privacy Protection Act, all users of our Website may make any changes to their information at any time by logging into their account and changing their information. we will not distribute their PII to outside parties without their consent.

Children Online Privacy

Anyone under 13 years of age should not access our Website and should not use our Products and Services without parent consent and guidance. Our Website and Services are not intended for children under 13, and we will not knowingly collect any information from any children under the age of 13. The Products and Services we offer though our Website are intended for a general audience of users 18 and older. We do not knowingly collect PII from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with PII, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that we have collected PII from your child, please contact us at: legal@tutorac.com.

Security Not Guaranteed

We use reasonable organizational, technical, and administrative measures to protect each Registrant’sPII under our control. However, we cannot guarantee 100% percent protection and security of such PII. Please do not email or text us credit card information and/or other sensitive personal or financial information.

What we Don’t do with the Information we Gather

We will not disclose, sell, distribute, rent, lease or use any of a Registrant’s data or pass on any such PII to third parties, which are not our officers, directors, members, managing members, employees, business partners, affiliates, strategic partners, licensors, licensees, independent contractors, third party service providers, agents or representatives, unless we have your permission or are required by law to do so.

We do not store your credit card information. The credit card information and actual processing does not take place and is not stored on our servers. The transaction is processed on the servers of the particular credit card processor we use to process the transaction.

Security

We are committed to ensuring that PII is secure. All non-financial information and Content provided to us is stored on our secure servers. In order to prevent unauthorized access or disclosure, we have taken all reasonable steps and put in place suitable safeguards to secure the information we collect from Registrants online.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will use our reasonable best efforts to protect each Registrant’s personal data, we cannot guarantee the security of their data transmitted to our Website; any transmission is at the risk of each Registrant. Once we have received PII, we will use the necessary procedures and security features to try to prevent unauthorized access. We will take all reasonable steps necessary to ensure that PII and data is treated securely and in accordance with this P​rivacy P​olicy.

Contact Us

Please email us at support@tutorac.com if you would like to access your PII, request that your PII be removed from our data base, or to have your information updated, changed or modified.

Links to Third Party Sites

Our Website may contain links to other third party sites. However, once Registrants have used these links to leave our Website, they should note that we do not have any control over the third party site being visited. Therefore, we cannot be responsible or liable for the protection and privacy of any information provided or which is obtainable when visiting those third party sites which are not governed by this Privacy Policy or our Terms of Use. To the extent that you access or use the Service through or on another third party site or application, then the privacy policy of that third party site or application will apply to your access or use of that site or application. we encourage ourRegistrants to read the privacy statements of other third party sites or applications before proceeding to use them.

Access to and Control Over Information we Send Registrants

From time to time we may send Registrants emails about special offers, discounts, products, or additional Products and Services available through our Website. Registrants can opt out of receiving our emails by clicking the unsubscribe button in the email.