Last revised 03/11/2020; effective as of: Apr 13, 2019
At Kapeesh, we have a few fundamental principles:
We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
We store personal information for only as long as we have a reason to keep it.
We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
We aim for full transparency on how we gather, use, and share your personal information.
Note about children: If you are under 13, you may use our website only with consent from parent or guardian. If found that we have unknowingly collected Personally Identifiable Information from children under 13, we take immediate measures to delete the information from our servers and discontinue or cancel their accounts.
Data we collect
What Information do we Collect?
You will be required to establish an account in order to take advantage of certain features of the Kapeesh Service. If you wish to establish an account you will be required to provide us with information (including personally identifiable information and non-personally identifiable information). In addition, we may obtain your personally identifiable information from you if you identify yourself to us by sending us an e-mail with questions or comments.
Depending on your use of the Kapeesh Service, we collect two types of information:
Personally Identifiable Information: identifies you or can be used to identify or contact you. Examples of personally identifiable information include your name, IP address, company/school name, address, e-mail address, telephone number, and billing and credit card information.
Non-personally identifiable information: is information, any single item of which, by itself, cannot be used to identify or contact you, including demographic information (such as age, profession, company industry, gender, current location, or zip code), IP addresses, browser types, domain names, and statistical data involving the use of the Kapeesh Service.
Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your account preferences).
We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a Kapeesh account to provide an email address, first name, and last name. We may ask you to optionally provide demographic or other information such as your school, gender, age or birthdate, zip code, and information about your interests and preferences.
Public Profile Information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a Kapeesh account, your username is part of that public profile, along with any other information you put into your public profile, such as a photo or an “About Me” description. Your public profile information is just that –public – so please keep that in mind when deciding what information you would like to include.
Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.
Communications with Others on Our Platforms. The Services may allow community members to communicate and collaborate with each other, including some Services that allow community members to engage in one-on-one communication using a video chat or text chat feature. Our servers may record, and we may retain records of the content of any such user-to-user communications.
Payment and Financial Information. We will process your payment information if you purchase products or services through our Services. Note that we do not store payment credit or debit card numbers.
If you utilize the Services in a way that necessitates payment from Kapeesh to you (such as offering tutoring services through Kapeesh or participating in our affiliate program), we may collect additional information from you, such as your bank account information, social security number, or taxpayer identification number, as necessary to facilitate payment and to comply with related legal obligations.
Registration to become a Kapeesh Tutor: When you register to be a Kapeesh Tutor, we will collect information from you such as your education and employment history, phone number, photo, country of residence, and information we need to process payments to you, such as your bank account information, social security number, or taxpayer identification number, as necessary to facilitate payment and to comply with related legal obligations.
Communications With Us: You may also provide us information when you respond to surveys, communicate with us about a support question.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
Information we collect automatically
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the Services: We may collect certain information automatically when you use the Services including your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet or mobile service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services, including the features you use, the questions you ask, the chats you have with our tutors, the type, size and filenames of attachments you upload to the Services. We may use your IP address and/or country in order to approximate your location. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page, clicked on a particular advertisement, or opened a particular email.
Embedded Scripts: Embedded scripts are programming code designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third-party service provider and is deactivated or deleted when you disconnect from the Services.
Flash & HTML5: We use Local Storage Objects (LSOs) such as HTML5 to store content, information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 & Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
Log files: We collect non-personally identifiable information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Kapeesh Service. This information may be used to analyze trends, to administer the Kapeesh Service, to monitor the use of the Kapeesh Service, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes, such as personalizing your experience on the Kapeesh Service, and evaluating the Kapeesh Service in general.
Information we receive from other sources
We receive information about you from other Service users, from third party services, and from our business and channel partners.
Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, we may receive your email address from other Service users when they provide it in order to invite you to the Services.
Other partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in, and engagement with, our Services and online advertisements. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email address or other contact information, profile picture, activities such as test completion and results, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services
Analytics: We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.
How we use your information
We only collect information about you if we have a reason to do so – for example, to provide our Services, to communicate with you, or to make our Services better. We do not sell any data, including your personal data. We will only process your personal data in accordance with applicable data protection and privacy laws.
We need certain personal data in order to provide you with access to Kapeesh Services. If you registered with us, you will have been asked to check a tick box indicating your agreement to provide this data in order to access our services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this policy, please do not use our platform.
Our uses of your personal information falls into the following general categories:
Strictly Necessary: Technologies necessary to set up and maintain your account, providing access to certain areas, functionalities, and features of our Services, support the shipping, tracking and recovery of your orders (such as SAT guides/books), communicating with you about your account, activities on our Services and policy changes, processing your financial information and other payment methods for products or Services purchased, and allowing you to register for live sessions and other events. In addition, we may use applications and tools to identify irregular site behavior, prevent fraudulent transactions and other illegal activities, improve security, fight spam, and protect the rights and property of Kapeesh and others.
Improvement of our Services: for example, by adding new features that we think our users will enjoy or will help them to create and manage their profiles more efficiently.
Personalization: The collection and processing of information about your use of these Services to subsequently personalize advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content you interact with on the Services is used to make inferences about your interests, which inform future selection of advertising and/or content.
Communication: By providing Kapeesh your email address and/or phone number, you consent to our using the email address and/or phone number to send you Service-related notices and receipts, including any notices required by law, in lieu of communication by postal mail.
You also agree that we may send you notifications of activity on the Service to the email address and/or phone number you give us, in accordance with any applicable privacy settings. We may use your email address and/or phone number to send you other messages, such as newsletters, changes to features of the Service, or special offers.
If you do not want to receive such email messages, you may opt out by selecting “unsubscribe” at the bottom of our email correspondences or STOP in text correspondences. Opting out may prevent you from receiving email messages and/or texts regarding updates, improvements, or offers. You may not opt out of Service-related e-mails.
Sharing Content with Friends or Colleagues: We may offer referral features whereby users may invite friends to use the Services. If you choose to use our invitation service to invite a friend to the Service, we will ask you for that person’s email address and/or phone number and automatically send them an email invitation or text. Kapeesh stores this information to send this email or text, to register your friend if your invitation is accepted, and to track the success of our invitation service. Your friend may contact us at email@example.com to request that we remove this information from our database.
Testimonials: We display personal testimonials of satisfied customers on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Measurement: The collection of information about your use of the content, and combination with previously collected information, used to measure, understand, and report on your usage of the Services.
System Administration: assisting in diagnosing problems with our servers, monitoring system performance and traffic on our Services and to gather broad demographic information about users.
Content selection, delivery, reporting: The collection of information, and combination with previously collected information, to select and deliver content for you, and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether the you took any action related to the content, including for example clicking on content.
Ad selection, delivery, reporting: Select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase.
Marketing: Emails and/or text messages about offers and promotions offered by Kapeesh and others we think will be of interest to you, solicit your feedback, or keep you up to date on Kapeesh and our products.
Disclosing your information to third parties
Sweepstakes, Contests and Promotions: We may offer sweepstakes, contests, and other promotions ("Promotion") that may require registration. By participating in a Promotion, you are agreeing to governing terms, conditions or official rules, which may contain specific requirements of you, including allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information, such as your name and shipping address, may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.
Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, registrars, registries, and data escrow services that allow us to provide domain registration services, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), and those that help us understand and enhance our Services (like analytics providers).
Advertising Partners. Through our Services, we may allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit the third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
International Data Transfers. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
Non-personally Identifiable Information. We may share non-Personal Information (such as aggregate user statistics, de-identified information, demographic information such as gender, age, graduation years, and other scholastic-related information), and Usage Information with third parties, including advertisers, content providers, and analytics providers; and third parties may collect non-Personal Information when you visit the Services.
In all scenarios, you are deemed to consent to disclosure of your information for the above purposes. If your Personal Information is shared with third parties, those third parties may be, but are not always, subject to appropriate agreements with Kapeesh to secure and protect the confidentiality of your Personal Information.
What are your choices?
You have several choices available when it comes to information about you:
Withdraw consent: Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below.
Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
Set Your Browser to Reject Cookies: At this time, Kapeesh does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Kapeesh websites, with the drawback that certain features of Kapeesh websites may not function properly without the aid of cookies.
The online advertising industry provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, www.youronlinechoices.eu/, youradchoices.ca/en/tools, and www.aboutads.info/choices/.
Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services, you can close your account. Please keep in mind that we may continue to retain your information after closing your account when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
What are your rights?
Customers have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can contact us in order to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to Contact Us to find out how to reach us.
You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.
Is your data secure?
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
All Company employees, contractors and agents who access Personal Information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of Personal Information.
Some or all of the Personal Information we collect may be stored or processed on servers located outside your jurisdiction of residence, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts or law enforcement in those jurisdictions according to laws in those jurisdictions.
California Privacy Rights
Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain categories of personal information during the preceding year for the third parties' direct marketing purposes and the categories of personal information the company shares.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: email@example.com or write to us at the following mailing address: Kapeesh, Inc., 4261 Ruthelma Ave., Palo Alto, CA 94306 United States.
You must put the statement "Your California Privacy Rights" in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Upon receiving a request, we will verify your request using the information associated with the Kapeesh Services, including your email address. We may need you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, including providing a government-issued ID. We endeavor to respond to a verifiable consumer request within 45 days of its receipt.
Whom do I contact if I have any privacy questions?
4261 Ruthelma Ave.
Palo Alto, CA 94306
4261 Ruthelma Ave.
Palo Alto, CA 94306
We ask that you not send or disclose to us any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise.
If you send or disclose any sensitive personal data to us when you submit user-generated content to Services, you consent to our processing and use of such sensitive personal data in accordance with this policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our platform.