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Privacy Policy

Definitions and legal references

This Website (or this Application)

The property that enables the provision of the Service.

The Owner (or We)

Tution360 – The natural person(s) or legal entity that provides this Website and the Service to Users.

User (or You)

The natural person or legal entity that uses this Website.

Service

The service provided by this Website is described in these Terms and on this Website.

Personally Identifiable Information

Refers to any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains, including, but not limited to, name, address, phone number, fax number, email address, financial profiles, social security number, and credit card information. 

Personally Identifiable Information does not include information collected anonymously (without identification of the individual user) or demographic information not connected to an identified individual.

Cookies

A cookie is a string of information that a website stores on a visitor’s computer and the visitor’s browser provides to the Website each time the visitor returns.

Data Controller, for the GDPR (General Data Protection Regulation), refers to the Company as the legal person who, alone or jointly with others, determines the purposes and means of processing Personal Data.

Privacy Policy of https://tution360.com

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

This Application collects some Personal Data from its Users.

Owner and Data Controller

Tution360

Owner contact email:

ian@tution360.com

This document contains a section dedicated to Brazilian Users and their privacy rights.

What is Personally Identifiable Information collected?

We may collect basic user profile information from all of our Users. We collect the following additional information from our Users: the name, email address, phone number, address, and social media profile information, that the User intends to purchase or sell.

For GDPR, Personal Data means any information relating to You, such as a name, an identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been entirely performed.

Personal Data collected for the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a more extended period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a more extended period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

What organizations are collecting the information?

In addition to our direct collection of information, our third-party service vendors (such as credit card companies, clearinghouses and banks) who may provide such services as credit, insurance, and escrow services may collect this information from our Users.

We do not control how these third parties use such information, but we ask them to disclose how they use personal information from Users. Some of these third parties may be intermediaries acting solely as links in the distribution chain and not storing, retaining, or using the information given.

Detailed information on the processing of Personally Identifiable Information is shown below:

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in banners and other advertisements on this Website, possibly based on User interests.

Google Ad Manager (Google LLC)

Google Ad Manager is an advertising service provided by Google LLC that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner unless otherwise specified in this document, has no direct relationship with. This service uses the “DoubleClick” Cookie, which tracks the use of this Website and User behaviour concerning ads, products and services offered.

Personal data processed: Cookies, Usage Data

Place of processing: United States –  Privacy Policy 

Google AdSense (Google LLC)

Google AdSense is an advertising service provided by Google LLC. This service uses the DoubleClick Cookie, which tracks the use of this Website and User behaviour concerning ads, products and services.

Personal data processed: Cookies, Usage Data

Place of processing: United States –  Privacy Policy  –  Opt-out 

Analytics

The services in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behaviour.

Google Ads Conversion Tracking (Google LLC)

Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Website.

Personal data processed: Cookies, Usage Data

Place of processing: United States –  Privacy Policy 

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC. Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its advertising network.

Personal data processed: Cookies, Usage Data

Place of processing: United States –  Privacy Policy  –  Opt-out 

How does the Website use Personally Identifiable Information?

We use Personally Identifiable Information to customize the Website, make appropriate service offerings, and fulfil buying and selling requests on the Website. We may email Users about research or purchase and selling opportunities on the Website or information related to the Website’s subject matter.

We may also use Personally Identifiable Information to contact Users in response to specific inquiries or to provide requested information.

We may also use your personal information for other reasons, such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened, or we suffer actual damage. 

If we notify you, we will only use your personal information for different, unrelated, or incompatible purposes.

With whom may the information be shared?

We may share Personally Identifiable Information and aggregated information about our Users, including the demographics of our Users, with our affiliated agencies and third-party vendors.

We also offer the opportunity to “opt-out” of receiving information or being contacted by us or any agency acting on our behalf.

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You access or visit our Service. Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service through their Privacy Policies and to enable Us to:

  • Measure and analyze traffic and browsing activity on Our Service
  • Show advertisements for our products and services to You on third-party websites or apps
  • Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies.

 You can use the following third-party tools to decline the collection and use of information to serve You interest-based advertising:

You may opt out of all personalized advertising by enabling privacy features on Your mobile device, such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows third-party vendors to recognize and deliver Your ads across devices and browsers. 

To read more about the technologies used by these third-party vendors and their cross-device capabilities, please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

How is Personally Identifiable Information stored?

Personally Identifiable Information collected by Tution360 is securely stored and is not accessible to third parties or employees of Tution360 except for use as indicated above.

What options are available to Users regarding the information’s collection, use and distribution?

Users may opt out of receiving unsolicited information from or being contacted by us and our vendors and affiliated agencies by responding to emails as instructed or by either :

  • Emailing us at: ian@tution360.com

Are Cookies Used on the Website?

Cookies are used for a variety of reasons. We use Cookies to obtain information about the preferences of our Users and the services they select. We also use Cookies for security purposes to protect our Users. For example, if a User is logged on and the Website is unused for more than 10 minutes, we will automatically log the User off. 

Users who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Tution360, with the drawback that certain features of the Website may not function properly without cookies.

Cookies used by our service providers

Our service providers use cookies, which may be stored on your computer when you visit our Website. You can find more details about which cookies are used in our cookies info page.

How does Tution360 use login information?

Tution360 does not use login information.

What partners or service providers can access Personally Identifiable Information from Users on the Website?

Tution360 has entered into and will continue to enter into partnerships and other affiliations with several vendors. Such vendors may have access to certain Personally Identifiable Information on a need to know the basis for evaluating Users for service eligibility. 

Our privacy policy does not cover their collection or use of this information—disclosure of Personally Identifiable Information to comply with the law. We will disclose Personally Identifiable Information to comply with a court order, subpoena, or request from a law enforcement agency to release information. We will also disclose Personally Identifiable Information when reasonably necessary to protect the safety of our Users.

How does the Website keep Personally Identifiable Information secure?

All of our employees are familiar with our security policy and practices. The Personally Identifiable Information of our Users is only accessible to a limited number of qualified employees who are given a password to gain access to the information. 

We audit our security systems and processes regularly. Sensitive information, such as credit card numbers or social security numbers, is protected by encryption protocols to protect information sent over the Internet. 

While we take commercially reasonable measures to maintain a secure site, electronic communications and databases are subject to errors, tampering, and break-ins. We cannot guarantee or warrant that such events will not occur, and we will not be liable to Users for any such occurrences.

GDPR Privacy

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Data and to guarantee. You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Data.The right to access, update or delete the information We have on You. You can access, update or request the deletion of Your Data directly within Your account settings section whenever possible. If you cannot perform these actions yourself, don’t hesitate to contact us to assist. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information. We hold about You corrected.
  • Object to processing of Your Data. This right exists where we rely on legitimate interest as the legal basis for Our processing. Something about Your particular situation makes You want to object to our processing of Your Data on this ground. You also have the right to object where We are processing Your Data for direct marketing.
  • Request the erasure of Your Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Data. We will provide your data to You or a third party You have chosen in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information. You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your Consent. You have the right to withdraw Your permission to use your Data. If You cancel Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

LGPD Privacy

Information for Users residing in Brazil

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Website and, if the case may be, its parent, subsidiaries and affiliates (for this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (Users are referred to below simply as “you”, “your”, or “yours”). For such Users, these provisions supersede any possibly divergent or conflicting conditions in the privacy policy.

This section of the document uses the term “personal information” as it is defined in the Lei Geral de Proteção de Dados (LGPD).

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows :

  • your consent to the relevant processing activities;
  • Compliance with a legal or regulatory obligation that lies with us;
  • the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
  • studies conducted by research entities, preferably carried out on anonymized personal information;
  • The carrying out of a contract and its preliminary procedures in cases where you are a party to said contract;
  • the exercising of our rights in judicial, administrative or arbitration procedures;
  • protection or physical safety of yourself or a third party;
  • the protection of health – in procedures carried out by health entities or professionals;
  • Our legitimate interests provided that your fundamental rights and liberties do not prevail over such claims; and
  • Credit protection.

To learn more about the legal bases, you can contact us any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, read the section “Detailed information on the processing of Personally Identifiable Information” within this document.

Why do we process your personal information?

To find out why we process your personal information, read the section “Detailed information on processing Personally Identifiable Information” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to :

  • Obtain confirmation of the existence of processing activities on your personal information;
  • access to your personal information;
  • Have incomplete, inaccurate or outdated personal information rectified;
  • Obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information or of information that is not being processed in compliance with the LGPD;
  • Obtain information on the possibility to provide or deny your consent and the consequences thereof;
  • Obtain information about the third parties with whom we share your data;
  • Obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
  • Obtain the deletion of your personal information being processed if the processing was based upon your consent unless one or more exceptions are provided in art. 16 of the LGPD apply;
  • Revoke your consent at any time;
  • Lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
  • Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
  • Request clear and adequate information regarding the criteria and procedures used for an automated decision; and
  • Request the review of decisions made solely based on the automated processing of your personal information, which affects your interests. These include decisions to define your personal, professional, consumer and credit profile or aspects of your personality.

You will never be discriminated against or otherwise suffer any sort of detriment if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document or via your legal representative.

How and when we will respond to your request

We will strive to respond promptly to your requests.

In any case, should it be impossible for us to do so, we’ll communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. 

In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your submissions if we are in the position to do so.

If you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will respond in a simplified fashion or if you need a complete disclosure.

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

If you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves a disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases :

  • when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the lawful means provided by international law;
  • when the transfer is required to protect your life or physical security or those of a third party;
  • when the ANPD authorizes the transfer;
  • when the transfer results from a commitment undertaken in an international cooperation agreement;
  • when the transfer is necessary for the execution of a public policy or legal attribution of public service;
  • when the transfer is required for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to an agreement, or the regular exercise of rights in judicial, administrative or arbitration procedures.

How can Users correct any inaccuracies in Personally Identifiable Information?

Users may contact us to update Personally Identifiable Information about them or to correct any inaccuracies by either:

  • Emailing us at: ian@tution360.com

Can a User delete or deactivate Personally Identifiable Information collected by the Website?

We provide Users with a mechanism to delete/deactivate Personally Identifiable Information from the Website’s database by contacting us. However, because of backups and records of deletions, it may be impossible to delete a user’s entry without retaining some residual information. 

An individual who requests to have Personally Identifiable Information deactivated will have this information functionally deleted, and we will not sell, transfer, or use Personally Identifiable Information relating to that individual in any way moving forward.

User rights

These are summarized rights that you have under data protection law:

  • The right to access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to object to processing
  • The right to data portability
  • The right to complain to a supervisory authority
  • The right to withdraw consent

Links to other websites

https://tution360.com contains links to other websites. Please note that when you click on one of these links, you are moving to another website. We encourage you to read the privacy statements of these linked sites, as their privacy policies may differ from ours.

How Can You Contact Us About This Notice?

If you have questions or comments about this notice, email us at ian@tution360.com or by clicking here.

How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form by clicking here.

Cookies And Web Beacons

Like any other website, Tution360 uses ‘cookies’. These cookies store information, including visitors’ preferences and the pages on the Website that the visitor accessed or visited. The data is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and other information.

Google DoubleClick DART Cookie

Google is one of the third-party vendors on our site. It also uses cookies, known as DART cookies, to serve ads to our site visitors based upon their visit to www.website.com and other sites on the Internet. However, visitors may choose to decline the use of DART cookies by visiting the Google ad and content network Privacy Policy at the following URL – https://policies.google.com/technologies/ads

Do We Make Updates To This Notice?

Yes, we will update this notice to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. 

If we make material changes to this privacy notice, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. 

We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

Last Updated: August 15, 2023