Privacy Policy

Last Updated: February 15, 2021

Conversations Unbound, Inc. (“Conversations Unbound,” “we,” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy. This privacy policy explains our policies and procedures regarding the collection, use, disclosure, and security of certain personal data that we receive, with a focus on personal data that would be considered “personal data” within the meaning of the EU General Personal data Protection Regulation (“GDPR”). As used in this privacy policy, “personal data” refers to information about an identified or identifiable individual, such as their name or email address.

 

Conversations Unbound provides a language-learning platform (the “Learning Platform”) that enables tutors to connect with university and independent students that need language tutoring. For the purposes of the GDPR, Conversations Unbound is considered the personal data controller. This means that we are responsible for deciding how we use the personal data that we hold. We are a New York 501(c)(3) organization registered in the United States with an office at PO Box 441978, Somerville, MA 02144.

The GDPR applies to you if you are located in the European Economic Area, the United Kingdom or Switzerland (an “EEA Individual”).

Please note that by registering with Conversations Unbound to become a tutor or a student, or providing or receiving tutoring, or visiting or using www.conversationsubound.org (the “Site”) and the various other related services, features, functions, software, applications and websites associated with the Learning Platform (together with the Learning Platform and the Site, collectively, the “Conversations Unbound Services”), you are accepting the practices described in this privacy policy, subject to any rights or restrictions that might apply under the GDPR if you are an EEA Individual, including the rights described in the European Privacy Rights for EEA Individuals provisions below. Our Terms of Service located at www.conversationsunbound.org/terms govern your use of the Learning Platform and the other Conversations Unbound Services (as modified, the “Terms”).  Capitalized terms that are not defined in this privacy policy shall have the meaning given to them in the Terms.

This policy describes the types of personal data we may collect from you or that you may provide when you create an account to provide tutoring as a tutor or receive tutoring as a student or you access or use the Learning Platform, the Site, the other Conversations Unbound Services or any of the other features, functions, services, and products and products, and our practices for collecting, using, maintaining, protecting and disclosing that personal data.

This policy applies to information we collect or may collect:

  • In creating an account to provide tutoring as a tutor or receive tutoring as a student.

  • In accessing and using the Learning Platform, the Site and the other Conversations Unbound Services.

  • In e-mail, text and other electronic messages or other content sent through or use of the Learning Platform, Conversations Unbound Services, the Site and the other Conversations Unbound Services.

  • Through services provided to us or to you by third-party companies, agents or contractors.

 

It does not apply to personal data collected by:

  • Us offline or through any other means, including on any other website operated by Conversations Unbound or any third party; or

  • Any third party, including our university partners.

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Please read this policy carefully to understand our policies and practices regarding your personal data and how we will treat this data. If you do not agree with our policies and practices, your only choice is not to access or use the Learning Platform or any of the other Conversations Unbound Services. By accessing or using the Learning Platform or any of the other Conversations Unbound Services, you agree to this privacy policy. This policy may change from time to time as described in the provision of this privacy policy entitled Changes to Our Privacy Policy.

Minors Under the Age of 18

None of the Conversations Unbound Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Learning Platform, the Site or the other Conversations Unbound Services. We do not knowingly collect personal data from minors under 13. If you are under 13, do not use or provide any information on or through any of the Learning Platform, the Site or any of the other Conversations Unbound Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name, username you may use or any pictures of you. If we learn we have collected or received personal data from a minor under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a minor under 13, please contact us at info@conversationsunbound.org.

FERPA

Conversations Unbound complies with all applicable provisions of the United States Family Educational Rights and Privacy Act, 20 U.S.C. 1232g, 34 CFR Part 99 (as amended, “FERPA”) in receiving and handling personally identifiable personal data and information from education records as a “school official” under FERPA. If you would like more information on your rights with respect to your educational record under FERPA, please visit the FERPA site.

Personal data we collect about you and how we collect it

We collect or may collect several types of personal data from and about you and other users of  the Learning Platform, the Site and the other Conversations Unbound Services, including: 

  • Personal data by which you may be personally identified, including personal data such as name, e-mail address, phone number, SKYPE ID and profile picture; 

  • Device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information;

  • Information that is about you but individually does not identify you, such as the date and time of visit;

  • IP address; 

  • Information that is about you but individually does not identify you, such as the date and time of your visit;

  • Geo-location information;

  • When you report a problem with the Learning Platform or any of the other Conversations Unbound Services;

  • Records and copies of your correspondence (including e-mail addresses), if you contact us; and/or

  • Details of transactions you carry out through the Learning Platform, the Site and any of the other Conversations Unbound Services.

 

We collect this personal data:

  • Directly from you when you provide it to us.

  • Automatically as you navigate through or use the Learning Platform, the Site or any of the other Conversations Unbound Services.

  • From third parties, such as our university partners, business partners and other third parties that provide us or you with certain services.

 

Certain transactions may also involve you calling us or our calling you. Please be aware that we may monitor, and in some cases, record such calls for staff training or quality assurance purposes.

Personal data minimzation

We take every reasonable step to limit the volume of your personal data that we process to what is reasonably necessary.

We do not engage in automated decision-making without human intervention

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

Consequences of not providing personal data

You are not required to provide all personal data identified in this policy to use our Site or to interact with us offline, but you will not able to use the Learning Platform or provide or receive tutoring if you do not provide the required personal data. In addition, if you do not provide the personal data, we may not be able to respond to you.  

Use of Cookies and Other Tracking Technologies

The technologies we use for automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.

Do Not Track Policy

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable personal data about your online activities over time and across third-party websites or online services. At present, no universally accepted standards exist on how companies should respond to do-not-track signals. In the event a final universally accepted standard is established, we will assess and provide an appropriate response to these signals.