Privacy Policy

Our Policy

Welcome to the platform (the “Platform”) of EdThinking, Inc. (“EdThinking”). EdThinking is a service that allows parents or guardians to enroll students in online small-group classes, and for teachers to create, publicize, and provide those classes (the “Services”). This Privacy Policy sets forth EdThinking’s policy with respect to the information collected from visitors and users of the EdThinking Services. 

 

Information We Collect

When you interact with us through the Services, we may collect information that, alone or in combination could be used to identify you (“Personal Data“) and other information from you, as further described below:

 

Personal Data That You Provide Through the Platform: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries or register for an EdThinking account to access the Services. We may collect the following information from you in order to provide our Services:

  • Name or publicly posted name from a Google linked account;

  • Email address;

  • Phone number;

  • Zip code or city and state you are located in;

  • Credit card or other payment information;

  • Your child’s first name;

  • Your child’s age or birthday;

  • Your child’s email address;

  • Video recordings of your child during classes;

  • Your voluntarily provided profile picture or your Google picture linked to your account;

  • Information voluntarily provided in the “about me” section of your profile;

  • Information voluntarily provided through reviews; and

  • Notes you provide to teachers about yourself or your child when enrolling a student.

 

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to our Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of EdThinking and the authorized third parties referred to herein.

 

Other Information

Passively Collected Data: When you interact with us through the Platform, we receive and store certain data automatically. EdThinking may store such passively collected data itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Platform, the number of visitors to each page of our website, and the domain names of our visitors' Internet service providers.

 

In operating our Platform, we and third parties that provide certain functionality to the EdThinking Services may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Platform. Our cookies help provide additional functionality to our Services and help us analyze Platform usage more accurately. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of our Services’ features. For more information about our use of cookies, please see the section entitled “Cookie Policy,” below.

 

Aggregated Personal Data: We may aggregate data, including Personal Data, and use such aggregated data for any purpose. This aggregate information does not identify you personally.

 

Our Use of Your Personal Data and Other Information

We use your information to:

  • provide the EdThinking Services;

  • process your payment for the Services;

  • send you emails or newsletters that you signed up for;

  • improve the EdThinking Services; and

  • analyze website usage.

 

EdThinking may provide the recording to Parents and the participants in the class to view. Please note that in some cases, Classes are taught by a “Teacher” that is actually an organization, group, or team of instructors (“Teacher Organization”). In such cases, Class Recordings may be accessed by the entire Teacher Organization, and access would not necessarily be limited to a single individual instructor. EdThinking may also use Class Recordings to provide feedback to Teachers, for customer support, and for compliance purposes.

 

EdThinking will obtain additional parental consent before we use any Class Recordings for promotional or other purposes. EdThinking and its affiliates may use your Personal Data to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each promotional communication we send you will contain instructions permitting you to "opt-out" of receiving future promotional information. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us at contact@EdThinking.com. Please note that we will continue to contact you via email to respond to requests and provide our Services.

 

Storage

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.

 

Our Disclosure of Your Personal Data and Other Information

We may share your Personal Data with certain third parties without further notice to you, as set forth below:

 

Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred to a successor or affiliate alone or as part of that transaction along with other assets.

 

Vendors and Service Providers: We engage third party vendors and service providers to perform certain functions on our behalf (such as payment processing). These third parties may have access to your Personal Data for the purpose of helping us market, provide and/or improve the Services.

 

Legal Requirements: EdThinking may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of EdThinking, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

 

Publicly Posted Information

You may be able to share Personal Data with third parties, including with the general public, through use of the Services.

 

User Profile: As a user of our Services, you will have a user profile that will be publicly available to all users of the Services (the “User Profile”). You are not required to include any Personal Data on your User Profile. But you will have the option to include a variety of types of Personal Data in your User Profile, which may include your first name, last name, biographical information, geographical location, and personal photograph.

 

We do not systematically monitor the content of information that is published on your user profile. Any information published in your User Profile becomes available to the public. After publishing, we have no control over how such information is used or its further dissemination. 

We urge you to think carefully about what, if any, Personal Data you include in your User Profile.

 

Public Forums: Our Services provide you the opportunity to share information on a variety of topics with other EdThinking Users through public forums (the “Public Forums”). Use of the Public Forums is entirely voluntary. But please be aware that any information you include in the Public Forums will become available to all EdThinking Users without restriction.

 

We do not systematically monitor the content of information that is published in the Public Forums. Any information published in Public Forums becomes available to the public. After publishing, we have no control over how such information is used or its further dissemination. We urge you to think carefully about what, if any, Personal Data you include in your posts on our Public Forums.

 

Children

This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by children under the age of 13 (“Child” or “Children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding Children’s personal information. For more information about COPPA and general tips about protecting Children’s online privacy, please visit OnGuard Online.

 

Collection: EdThinking collects information about students directly from Parents, who provide us with the Child’s first name, age, type of schooling, local time zone, and additional notes for the Teacher. In addition, Children may share information about themselves during Classes. The EdThinking class sessions may take place over online videos in which video images and audio of the Children are recorded. No information is collected directly from Children until they are in the course session. Children cannot post personal data publicly on the EdThinking Services.

 

Use and Disclosure: EdThinking shares the name, age, local time zone, and any notes Parents have provided about their Child to the Class Teacher, in order to allow the Teacher to provide Classes. This information shall also be treated as part of the Parent’s “Personal Data” and may be shared as described in the Disclosure section above for business transfers; to vendors and service providers; and to comply with legal requirements. Children may also share information about themselves with the Teacher and the rest of their class during the Class session voluntarily. While EdThinking expects Teachers and all other Users to abide by our standards of conduct, please note that we cannot control or monitor what personal information your Child shares with Teachers or other classmates, nor what those third parties ultimately do with that information, and we disclaim all responsibility in that regard.

 

Class Video Recordings: As described above, EdThinking records video of students and teachers during EdThinking classes (“Class Recordings”). The Class Recordings are made available by EdThinking to the Teacher of the Class and may be shared by the Teacher for the entire class (and their Parents) to view (the “Permitted Recipients”). Please note that in some cases, Classes are taught by a “Teacher” that is actually an organization, group, or team of instructors (“Teacher Organization”). In such cases, Class Recordings may be accessed by the entire Teacher Organization, and access would not necessarily be limited to a single individual instructor. EdThinking may also use Class Recordings to provide feedback to Teachers, for customer support, and for compliance purposes. EdThinking will obtain additional parental consent before we use any Class Recordings for promotional or other purposes. We utilize reasonable means to (i) limit the ability of Teachers to create copies of the Class Recordings or to share the Class Recordings with anyone aside from Permitted Recipients, and also (ii) limit the ability of Permitted Recipients to download or re-share the Class Recordings. While we expect Teachers and Permitted Recipients to abide by our standards of conduct, please note that we cannot control or monitor what such third parties ultimately do with Class Recordings, and disclaim all responsibility in that regard.

 

Parental Consent: EdThinking obtains verifiable parental consent before collecting Personal Data from your Child. EdThinking requires that you provide your credit card information in order to register your Child for and pay for an EdThinking Class. If you do not consent, then we will not collect, use or disclose any personal information about your Child, and your Child will not be allowed to use the Services in any way. If you are not using our services for any other purposes and do not provide consent within a reasonable time from the date the direct notice was sent, we will also delete your online contact information from our records.

 

Parental Choices and Controls: At any time, you can refuse to permit us to collect further Personal Data from your Children in association with your account, and can request that we delete from our records the Personal Data we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other services. You may update your Child’s information by logging onto your account. You can contact EdThinking to request access to, change, or delete your Child’s personal information by sending an email to us at contact@EdThinking.com. A valid request to delete personal information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal information belonging to Children when it is no longer needed for the purpose for which it was collected.

 

Links to Other Websites

This Privacy Policy applies only to EdThinking Services. The Services may contain links to other websites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we describe here do not apply to the Third-Party Sites. The links from our Services do not imply that we endorse or have reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

 

Social Media

When you log into the Site using your Google account, we will collect relevant information necessary to enable us to access your Google account; however, you will provide your login information, like your password, directly to Google (and not to EdThinking). As part of such integration, Google will provide us with access to certain information that you have provided to Google, and we will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of Google. However, please remember that the manner in which Google uses, stores and disclose your information is governed by the policies of Google, and, as a result, EdThinking shall not have any liability or responsibility for the privacy practices or other actions of Google that may be enabled within and/or otherwise accessible through our Services.

Security

We take reasonable steps to protect the Personal Data provided via the Services from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, the Internet cannot be guaranteed to be fully secure and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for disclosures beyond our reasonable control. You are also responsible for helping to protect the security of your account credentials. For instance, never give out your password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Data. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.

 

Do Not Track

Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. While we do not currently support Do Not Track signals, we treat the data of everyone who comes to our site in accordance with this Privacy Policy, whatever their Do Not Track setting.

Access and Accuracy; Correcting Personal Data.

You have the right to access the Personal Data we hold about you in order to verify the Personal Data we have collected with respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Data, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

 

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

 

In certain circumstances, you have the right:

  • To access and receive a copy of the Personal Data we hold about you

  • To rectify any Personal Data held about you that is inaccurate

  • To request the deletion of Personal Data held about you

 

You have the right to data portability for the information you provide to us. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.

 

Please note that we may ask you to verify your identity before responding to such requests.

 

Additional Notice for California Consumers

This portion of our Privacy Policy applies to California consumers only.

 

Personal Information Collected on California Consumers in the Last Twelve Months

 

We collect information from users, as described in our Privacy Policy. The “Personal Information,” as defined in California Civil Code § 1798.140(o), we have obtained on California residents within the last twelve months includes the following:

 

  1. Identifiers such as a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

  2. Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  3. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

  4. Geolocation data (excluding real time GPS information).

  5. Audio, electronic, visual, thermal, olfactory, or similar information.

  6. Professional or employment-related information.

  7. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

  8. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

Our Use of Personal Information for Business Purposes in the Last Twelve Months

 

We use the Personal Information we collect, identified in each of the above categories, for the business purposes disclosed within the Privacy Policy. These business purposes include the following:

 

  1. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

  2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

  3. Debugging to identify and repair errors that impair existing intended functionality.

  4. Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

  5. Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

  6. Undertaking internal research for technological development and demonstration.

  7. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

 

Sharing of Personal Information in the Last Twelve Months

 

Disclosures of Personal Information on California Consumers for Business Purposes: Within the last twelve months, we have disclosed Personal Information identified in the above categories only (i) for exempt activities, as part of a business-to-business transaction, (ii) at your express request, or (iii) for our business purposes. 

 

California Rights and Choices

If you are a California resident, you have certain legal rights related to your Personal Information. Except as otherwise provided by applicable law, you may exercise the following rights for purposes of the Personal Information covered by our Privacy Policy.

 

  1. Right to Know/Portability
    You have the right to request that we disclose to you certain information about Personal Information we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:

    • the categories of Personal Information we have collected about you;

    • the categories of sources from which the Personal Information is collected;

    • our business or commercial purpose for collecting Personal Information;

    • the categories of third parties with whom we share Personal Information; and

    • the specific pieces of information we have collected about you.

  2. Right to Opt Out
    We do not offer a right to opt out because we have not sold any Personal Information described in this Privacy Policy to third parties within the previous twelve months and will not sell Personal Information within the meaning of the CCPA.

  3. Right to Deletion
    You have the right to request deletion of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we confirm your verifiable request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
    We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

    • complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

    • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

    • debug products to identify and repair errors that impair existing intended functionality;

    • exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

    • comply with the California Electronic Communications Privacy Act;

    • enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

    • comply with a legal obligation; or

    • make other internal and lawful uses of that information that are compatible with the context in which you provided it.

  4. Right to Non-Discrimination for Exercise of a California Privacy Rights
    We will not discriminate against you because you exercise any of the above rights, or any other rights under the CCPA. Specifically, if you exercise your Rights, we will not deny you Services, charge you different prices or rates for Services or provide you a different level or quality of Services.

  5. How to Submit A Request
    You may submit a request to exercise the rights listed above by:

    • emailing us at contact@EdThinking.com.

    • In your request, please include (1) full name used to create your account; (2) email with which you created your account; (3) phone number in case we need to contact you to securely verify your request; (4) whether you are requesting how your information is used and/or to delete your personal information.

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

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

  8. Right to Opt Out and Right to Opt In
    Please note we do not sell Personal Information of California Consumers regardless of your age. If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt out”). We do not sell the Personal Information of consumers we know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to Personal Information sales may opt out of future sales at any time.

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

 

Other California Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Data which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: contact@EdThinking.com.

 

Cookie Policy

What are cookies?

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device.

 

What are cookies used for?

Cookies allow a site or services to know if your computer or device has visited that site or service before. Cookies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. Cookies can also help ensure marketing you see online is more relevant to you and your interests.

 

What types of cookies do we use?

There are generally four categories of cookies: “Strictly Necessary,” “Performance,” “Functionality,” and “Targeting.” We routinely use all four categories of cookies on the Service. You can find out more about each cookie category below.

 

  1. Strictly Necessary Cookies. These cookies are essential, as they enable you to move around the Service and use its features, such as accessing logged in or secure areas. Because these cookies are essential, they cannot be disabled.

  2. Performance Cookies. These cookies collect information about how you have used the Service, for example, information related to the unique username you have provided, so that less strain is placed on our backend infrastructure. These cookies may also be used to allow us to know that you have logged in so that we can serve you fresher content than a user who has never logged in. We also use cookies to track aggregate Service usage in an anonymized fashion and experiment with new features and changes on the Service. The information collected is used to improve how the Service works.

  3. Functionality Cookies. These cookies allow us to remember how you’re logged in, whether you chose to no longer see advertisements, when you logged in or out, and the state or history of Service tools you’ve used. These cookies also allow us to tailor the Service to provide enhanced features and content for you and to remember how you’ve customized the Service in other ways. The information these cookies collect are anonymous, and they are not used to track your browsing activity on other sites or services.

  4. Targeting Cookies. Us, our advertising partners, or other third party partners may use these types of cookies to deliver advertising that is relevant to your interests. These cookies can remember that your device has visited a site or service, and may also be able to track your device’s browsing activity on other sites or services other than ours. This information may be shared with organizations outside of ours, such as advertisers and/or advertising networks to deliver the advertising, and to help measure the effectiveness of an advertising campaign or other business partners for the purpose of providing aggregate Service usage statistics and aggregate Service testing.

 

How long will cookies stay on my device?

The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.

 

How to control and review cookies?

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

 

Other Terms and Conditions

Your access to and use of our Services is subject to the Terms of Service.

 

Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted, and any material changes will become effective 30 days from their posting on this page or via email to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Personal Data that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.

 

Contact Us

Please feel free to contact us if you have any questions about EdThinking’s Privacy Policy or the information practices of our Services.

 

You may contact us as follows: You may send an email to contact@EdThinking.com.