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.

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

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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.

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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.

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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.

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.

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.

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.

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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.

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

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.

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. 

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.

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.

We may use or partner with other third-party companies, agents or contractors for various purposes in connection with our business and operations (“Service Providers”), including, invoicing and payment processing, sending marketing communications, collecting and storing personal data, social media marketing, relationship building, the marketing and growth of our business and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your personal data. We may also share personal data, including your personal data, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. These Services Providers may have adopted their own privacy policies, which are not subject to control by Conversations Unbound. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your personal data. We do not list our current Service Providers because they change from time to time. If you would like the names of any of Service Providers, please email us at info@conversationsunbound.org. The Service Providers may also transmit cookies to your computer or device when you click on ads that appear on or through the Service.

As a convenience to you, we may in the future also provide links to other third-parties from within the Site or the other Conversations Unbound Services. If you click on one of these links, you will be redirected to that third-party’s site (via affiliate cookies) and such third party may also transmit cookies to you. We do not have any control over that or how they collect, use, maintain, protect and disclose your personal data. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any of the Conversations Unbound Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.

We use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics to improve the Learning Platform, the Site and the other Conversations Unbound Services and their related features, functionality and performance. Google Analytics collects only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser.

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You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to, you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

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DoubleClick: We may use Google Analytics and Google Adwords remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.

Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website.

The Site uses Google Ads to advertise on third party websites to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Site. Of course, any data collected will be used in accordance with this privacy policy, as well as Google’s privacy policy Google’s privacy policy.

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DoubleClick: We use “Google Ads” remarketing codes to log when users view specific pages or take specific actions on the Site. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out or the Network Advertising Initiative opt-out.

We will only use personal data that we collect about you or that you provide to us, including any personal data for purposes described in this privacy policy and when applicable law allows us to do so. We will generally use your personal data on the following legal grounds:

• Where the use of your personal data is necessary for the performance of a contract we are about to enter into or have entered into with you or pursuant to which we are providing services to you or on your behalf;

• Where the use is necessary for the purposes of our legitimate interests (or those of a third party);

• Where we need to comply with a legal or regulatory obligation; or

• Where you have given your consent (which can be withdrawn at any time). 

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We use personal data that we collect about you or that you provide to us, including any personal information:

• To enable you to provide tutoring as a tutor or receive tutoring as a student.

• To provide you access and use of the Learning Platform.

• To provide the Site, the other Conversations Unbound Services and the content that is on it to you.

• For login and security associated with the Learning Platform.

• To process and complete transactions, including the application to become a tutor, receiving payments from Students and transferring payments to Tutors and sending you related information.

• To ensure compliance with the Terms.

• To provide technical and other support to you.

• To track your usage of the Learning Platform and your engagement with your assigned Students or Tutors.

• To send you news or information about us that may be of interest to you. 

• To enable Service Providers to perform certain responsibilities and provide certain services in connection with the Learning Platform and our business and operations.

• To fulfill any other purpose for which you provide it.

• To provide you with notices about your account.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to the Learning Platform, the Site and the other Conversations Unbound Services.

• For quality control and to improve the Learning Platform and the other Conversations Unbound Services. 

• To enhance the safety and security of the Learning Platform and the other Conversations Unbound Services.

• To verify your identity and prevent fraud or other unauthorized or illegal activity.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

Some of the personal data that we collect automatically is statistical personal data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Learning Platform, the Site and the other Conversations Unbound Services, and to deliver a better and more personalized service, including enabling us to:

• Estimate our audience size and better understand usage patterns.

• Store personal data about your preferences, enabling us to customize the Site according to your individual interests.

• Speed up your searches.

• Recognize you when you return to the Learning Platform and the Site.

We may store any data or other information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the Learning Platform, the Site or any of the other Conversations Unbound Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Conversations Unbound and you. By allowing Conversations Unbound to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Learning Platform or the Site and view content faster.

Although users from all over the world may access the Learning Platform, the Site or any of the other Conversations Unbound Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.

We may disclose personal data that we collect or you provide as described in this privacy policy:   

• To the university that may be paying for your tutoring.

• To Service Providers, contractors and other third parties we use to support the Learning Platform and our business but only to the extent necessary for them to provide this support.

• To a potential or actual buyer, assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Conversations Unbound’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Conversations Unbound about users of the Site and the other Conversations Unbound Services is among the assets that may be or are actually transferred.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the personal data.

• With your consent.

We may also disclose your personal data:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.

• To enforce or apply the Terms and other agreements, including for billing and collection purposes.  

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Conversations Unbound, our customers, developers, users or others.

We have no current intention of otherwise selling any of your personal data. If that ever changes, we will notify you in accordance with the provision of this privacy policy entitled Changes to Our Privacy Policy.

We may use, disclose, share or sell personal data that is anonymized or in an aggregated form that does not include any personal data about you and we may use and share any such personal data for any purpose without restriction so long as we do not disclose any of your personal data or it does not violate the terms of this privacy policy or any applicable law.

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your personal data:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that all or some parts of the Learning Platform and the other Conversations Unbound Services, may then be inaccessible or not function properly.

• Promotional Offers from Conversations Unbound. If you do not wish to have your e-mail address/contact information used by Conversations Unbound to market or otherwise promote our own or third parties’ products or services, you can opt-out through the unsubscribe mechanism at the bottom of the applicable email. This opt-out does not apply to personal data provided to Conversations Unbound as a result of a service or product purchase, warranty registration, product service experience or other transactions.

We do not control third parties’ collection or use of your personal data to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at http://preferences-mgr.truste.com.

GDPR and the laws in some other jurisdictions require companies to tell you about the legal bases that they rely on to use or disclose your personal data. To the extent that those laws apply, we rely on the following legal grounds to process your personal data:

• Performance of a contract: In most cases, we collect and use your personal data and other information to meet our obligations under a contract to which you are a party or pursuant to which we are providing services to you. For example, when you use the Learning Platform or any of the other Conversations Unbound Services, we will use your personal data to respond to your requests and to provide you with these services. 

• Legitimate interests: We may use your personal data information for our legitimate interests on the grounds that it furthers our legitimate interests in commercial activities (but only to the extent that such interests are overridden by the interests or fundamental rights and freedoms of the affected individuals) including:

  • Analyzing and improving the Learning Platform, the other Conversations Unbound Services and our business

  • Providing the services pursuant to our contracts with our customers

  • Marketing

• Legal compliance: We may use and disclose personal data in certain ways to comply with our legal obligations under European or Member State law or other applicable law.

• Consent:  To the extent required by law, and in certain other cases, we handle personal data on the basis of implied or express consent.

You may change, correct or delete any personal data that you have provided to us through your account or by emailing us at info@conversationsunbound.org.

California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to info@conversationsunbound.org or write to us at: Conversations Unbound, Inc., PO Box 441978, Somerville, MA 02144.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your personal data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right by contacting us directly.

If you are an EEA Individual and GDPR applies and we hold your personal data in our capacity as a controller, you may request that we:

• Provide access to and/or a copy of certain personal data (including, in some cases, in portable form);

• Prevent the processing of your personal data for direct-marketing purposes (including any direct marketing processing based on profiling);

• Update personal data that is out of date or incorrect;

• Delete certain personal data which we are holding about you; provided that the personal data is not required by us for (i) compliance with a legal obligation under European or Member State law or other applicable law or (ii) the establishment, exercise or defense of a legal claim;

• Object to our processing of personal data;

• Restrict the way that we process and disclose certain of your personal data except to the extent that processing is required (i) to comply with a legal obligation under European Member State law or applicable law or (ii) for the establishment, exercise or defense of legal claims;

• Transfer your personal data to a third party to the extent that this is technically feasible; and

• Honor a revocation of your consent for the processing of your personal data (without retroactive effect).

We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain personal data may be exempt from such requests in some circumstances, which may include if we need to keep processing your personal data for our legitimate interests or to comply with a legal obligation. We may request you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern, as we would be happy to try to resolve it directly. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

If you are an EEA Individual in France, you also have the right to set guidelines for the retention and communication of your personal data after your death.

If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us at info@conversationsunbound.org if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

In addition, where you believe that we have not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Personal data Protection Authority, such as the UK Information Commissioner’s Office. Here is a list of local personal data protection authorities in EEA countries.

You can exercise any of these rights by contacting us at info@conversationsunbound.org or write to us at: Conversations Unbound, Inc., PO Box 441978, Somerville, MA 02144.

We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfill the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Personal data may persist in copies made for backup and business continuity purposes for additional time. 

We understand that the security of your personal data is important. We provide reasonable administrative, technical, and physical security controls to protect your personal data. However, despite our efforts, no security controls are 100% effective. Conversations Unbound cannot ensure or warrant the security of your personal data. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Learning Platform, the Site or the other Conversations Unbound Services.

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the home pages of the Site for at least 30 days. If we make material changes to how we treat our users’ personal data that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home pages of the Site and to attempt to get your consent to the changes. The date the privacy policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Site and this privacy policy to check for any changes.  Like our Terms, of which this privacy policy is a part, your use, and/or continued use after our efforts to contact you, of the Site, the Learning Platform or any of the other Conversations Unbound Services, means that you agree to be bound by such changes.

The policies indicated in this privacy policy will remain effective, even if the Terms and the other agreements between us are terminated and you are no longer using the Site, the Learning Platform or any of the other Conversations Unbound Services.

To ask questions or comment about this privacy policy and our privacy practices or need to reach us for any other reason, you may contact us by e-mail at info@conversationsunbound.org or by mail at Conversations Unbound, Inc., PO Box 441978, Somerville, MA 02144.