We at Engageli, Inc. ("Engageli", "us", "we", or "our") recognize and respect the importance of maintaining the privacy of users of our eClubHouse platform ("Platform"). This Privacy Notice describes the types of information we collect from and about you and your child when you and/or your child use our Platform and the services available thereon ("Services"). This Privacy Notice also explains how we collect, process, transfer, store, and disclose the information collected. If not otherwise defined herein, capitalized terms have the meanings given to them in the Terms of Service, available at https://www.eclub.house/terms ("Terms"). "You" means an individual using the Services as a parent or guardian of a minor whom you allow to use the Platform and the Services, and for whom you will be held strictly responsible.

 

"Personal Information" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Information is collected by us in connection with provision of the Platform and/or Services.

 

Personal Information We Collect 

 

We collect information from you when you choose to use our Platform and/or Services. In order to register to use our Platform and/or receive related Services, you will be required to provide us with certain Personal Information about you and/or your child, such as your name, email address, phone number, child's name, child's age, child's birthday, child's email (if applicable), areas of academic interest, and emergency contact (if not you). You may also choose to provide us with details of any health or learning issues or any other information related to special accommodations that may be necessary or desired. 

 

If you use the Services by logging in through a third-party login service, we may also receive Personal Information about you as provided by such third-party login service. Please check such third-party's policies in order to understand what information we receive. 

 

We collect any Personal Information included in any User Content or other materials that you or your child upload to the Platform. For example, you and/or your child may upload a profile picture, share a computer screen, send messages (including images) through a chat function, and may post a mood rating. You and/or your child may also choose to provide homework or school materials or other academic information. 

 

In addition, when using the Platform, certain information may automatically be gathered about your or your child's computer or mobile device, including non-Personal Information, such as the operating system, browser type, and connectivity speed, and Personal Information such as your IP address, device ID, location information based on your IP address, as well as your use and/or browsing history and any information regarding your usage history through the Platform. This includes information such as the time of login, the time spent on different activities along with different actions involved in activities (rewind, mute, focus mode, screen shot annotation, etc.), whether camera or microphone are connected, questions posted or answered, desktop sharing, use of chats and other communications, and feedback provided.  

 

It is your voluntary decision whether to provide us with any such Personal Information, but if you refuse to provide such information we may not be able to register you or your child to the Platform and/or provide you and/or your child with the Services. 

 

We rely on your consent for our collection and processing of your child's Personal Information. You are free to revoke this consent at any time and may do so by emailing us. In such case, your child will have no further access to the Platform.

 

How We Use Your Personal Information

 

General

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We and any of our trusted third-party subcontractors and service providers use the Personal Information we collect from and about you for any of the following purposes: (1) to provide you with the Platform and/or Services, including generating Reports; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to contact you with informational newsletters and promotional materials relating to our Platform and Services; (5) to review the usage and operations of our Platform and Services; (6) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (7) to prevent fraud, protect the security of our Platform and Services, and address any problems with the Platform and/or Services; and (8) to provide customer support. 

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Statistical Information and Analytics

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We and/or our service providers use analytics tools to collect and analyze information about the use of the Platform and/or Services, such as how often users visit the Platform, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Platform. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Platform and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires.

 

Limited Use

We will never sell Personal Information of your child or use such information for the purpose of behavioral targeting of advertisements to your child. 

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Sharing the Personal Information We Collect 

 

We share your information, including Personal Information, as follows:

 

Users and Coaches

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Certain Personal Information about you and/or your child that you provide through the Platform will be accessible to Coaches and other Users. You can manage what Personal Information will be shared by adjusting your settings. Please ensure that settings are configured in accordance with your privacy preferences.

 

Business Partners, Service Providers, Affiliates, and Subcontractors

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We disclose information, including Personal Information we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who use such information to: (1) help us provide you with the Platform and/or Services; and (2) aid in their understanding of how users are using our Platform and/or Services. 

 

By accepting this Privacy Notice, you acknowledge that we may use subcontractors and service providers who are located in countries other than your own and may send them information we receive (including Personal Information). All of our subcontractors and service providers will be subject to non-disclosure and non-use obligations. 

 

Business Transfers

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We may transfer our databases containing your and/or your child's Personal Information if we sell our business or part of it, including in cases of liquidation. Your and/or your child's Personal Information may be disclosed as part of, or during negotiations of, any merger, sale of Engageli's assets or acquisition (including in cases of liquidation) in such case, the Personal Information shall continue being subject to the provisions of this Privacy Notice.

 

Law Enforcement Related Disclosure

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We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may share your and/or your child's Personal Information with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.

 

Legal Uses

We may use your and/or your child's Personal Information as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

 

Security 

 

We make efforts to follow generally accepted industry standards to protect the Personal Information submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your and your child's Personal Information, we cannot guarantee its absolute security. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information. 

 

Your Rights

 

Subject to applicable law, you may have the right to request to review or inspect Personal Information you or your child have provided to us or that we have collected and request that such Personal Information be corrected, updated, or deleted. To the extent such rights apply under applicable law, you can exercise such rights by emailing us at support@eclub.house. 

 

Data Retention 

 

We retain information as necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above. Through the Platform you will be able to configure your settings to determine how long certain Personal Information will be retained. However, please note that certain analytics information may continue to be retained and used in accordance with this Privacy Notice. When possible, records of Personal Information are kept in a pseudonymized fashion.

 

Cookies and Similar Technologies

 

We use cookies and similar technologies for a number of reasons, including to help personalize your experience. 

 

What are Cookies?

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A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this user returns.

 

• A "session cookie" is temporary and will remain on your device until you leave the Platform.

• A "persistent" cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it. 

• First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.

• We may use the terms "cookies" to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or "pixel tags".

 

How We Use Cookies

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The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, we chiefly use cookies that are necessary in order to allow the Platform to work correctly. For example, cookies are used to enable you to access the Platform, move around, and access different services, features, and tools, and remember previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled. Certain cookies may also be used to provide added functionality, such as remembering your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.

 

How to Adjust Your Preferences

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Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.

 

Third-Party Applications and Services

 

All use of third-party applications or services is at your own risk and subject to such third party's privacy policies. 

 

Communications

 

We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account. 

 

Changes to the Privacy Notice

 

We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on the Platform If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Platform or via email. 

 

Comments and Questions

 

If you have any comments or questions about this privacy notice, please contact us at support@eclub.house. 

 

Last updated: October 2020