1. WHAT KIND OF INFORMATION WE COLLECT

We collect the following types of information below through your use of the Applications, the Thinkster Services and/or the Site.

1. Personal Information. “Personal Information” is information that identifies you or another person, which may be transmitted or received when you use an Application, the Thinkster Services and/or the Site. Personal Information includes your geographic location information, names, physical addresses, email addresses, telephone, fax and other device numbers, calendar entries stored within your Device, contact entries stored within your Device, files, content, photographs, location information and other metadata in photographs and other information you transmit or receive using an Application, the Thinkster Services, and/or the Site which identifies you or another person. Personal Information also includes information about you or others that may be accessed by our system directly from your Device, including from your address book, location, photos or contacts folder, in order to enable certain features of an Application or the Thinkster Services. Unless you have elected to opt-out of providing your geographic location information, the Applications may use and store information related to the geographic location of your device and combine this information with other Personal Information to provide certain services, whether or not the Application is active.

   We collect Personal Information if you provide it directly to us via email or through the Applications, the Thinkster Services or the Site. We may also collect Personal Information when you send us messages, comments, questions or suggestions or if you participate in blogs, forums, message boards, chat rooms, profile pages and other services to which you are able to post information, if any, on the Site (collectively, “Forums”).For quality purposes, we maintain a digital record of the sessions. This recording of the session is available to you and your child on our student app. We reserve the right to analyze the recorded data for such purposes as may be deemed suitable for enhancement of the course, quality of teaching, session experience etc. We may also collect Personal Information through certain features of one or more Applications or the Thinkster Services (and in some instances will allow you to opt-out of such collection or retention of certain Personal Information). In some instances, certain Applications do not have to be in active use in order for your Personal Information to be collected through them.

2. “Non-Personal Information” is information that does not identify you or any other individual, and includes Session and Usage Data, Log Data and Aggregate Information, each as described below.Session and Usage Data. “Session and Usage Data” is information about your use of an Application, the Thinkster Services and/or the Site and includes, without limitation, connection and service-related data submitted to us through your use of an Application, the Thinkster Services or the Site. Session and Usage Data includes information relating to the connection request, server communication and data sharing, including network measurements, quality of service, and date, time and location of the Thinkster. We also may aggregate Session and Usage data as described in Aggregate Information below. Please note that Session and Usage Data does not include any Personal Information, nor does it include Content you may transmit or share through the use of an Application (such as photos, contacts, calendar appointments, etc.), the Thinkster Services, or the Site.
3. Log Data. When you interact with us or use an Application, the Thinkster Services or our Site, our systems may automatically collect your unique User Device number, the IP address, type of browser or operating system you use, and the dates and times of your use (“Log Data”).
4. Aggregate Information. “Aggregate Information” is data we collect about a group or category of services or Users from which individual User identities have been removed. In other words, information on how you use the Applications, the Thinkster Services and the Site may be collected and combined with information about how others use the Applications, the Thinkster Services and the Site, but no personally identifiable information will be included in the resulting Aggregate Information. Aggregate Information helps us understand trends in our Users' needs so that we can better consider new features or otherwise tailor the Applications, the Thinkster Services and the Site.
5. Call Recording. We record calls to focus on you instead of taking notes, and for internal training purposes. Please do not share any sensitive personal information of any kind. We do not request and have no intention to collect this type of information. We also do not intend to record people around you.

2. HOW WE USE YOUR INFORMATION

1. Personal Information. We may use your Personal Information:
   1. To respond to your inquiries, fulfill your requests, provide services, or complete transactions you have requested.
   2. To send you information regarding an Application, the Thinkster Services and the Site, changes to our terms, conditions, and policies and/or other administrative information.
   3. To resolve problems with an Application, the Thinkster Services or the Site.
   4. To create an individual profile and provide personalized services, and to create and inform you of new products and services from us that better meet your needs.
   5. To better determine your location.
   6. As we believe to be necessary or appropriate: (a) in any manner permitted under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
2. Without limiting the generality of the foregoing, we may use data from tutoring sessions, phone calls, emails, and texts (including written, audio or video materials), to assist us in our internal quality control processes and to train and provide feedback to our tutors. Whiteboard tutoring sessions are also available for review in our Student and Parent Insights Apps.
3. Non-Personal Information. We may use Non-Personal Information for any purpose, including for our own internal purposes; to measure traffic patterns; to understand demographics, customer interest, and other trends among our Users; to provide, improve and modify the Applications, Thinkster Services and the Site; and for promotion and marketing purposes. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your unique User Device number). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined. We may display targeted advertisements based on Personal Information. Advertisers (including ad serving companies) may assume that people who interact with, view, or click targeted ads meet certain targeting criteria, such as females between 18-24 years of age from a particular geographic area. We do not provide any Personal Information to the advertiser when you interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will assume that you meet the targeting criteria used to display the ad.

3. HOW YOUR INFORMATION MAY BE DISCLOSED

1. Personal Information. In general, we use Session and Usage Data internally to serve our Users and enable them to take maximum advantage of the Applications, the Thinkster Services and the Site. We also store Personal Information to improve the functionality of the Applications, the Thinkster Services and the Site. All information collected is stored in our database and may be archived elsewhere. We may disclose your Personal Information:
   1. To our third party service providers who provide services such as website hosting, maintenance, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other similar services, but only to the extent necessary or useful to provide such services, and only pursuant to contractual obligations requiring such third parties to maintain the privacy and security of your Personal Information.
   2. To identify you to anyone to whom you send messages through an Application, the Thinkster Services or the Site.
   3. To identify you to other users of an Application to suggest you or they take advantage of certain features within Applications or the Thinkster Services.
   4. Provided by you on Forums freely and without limitation. Please note that any Personal Information you post or disclose on Forums will become public information and may be available to visitors of the Site. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Site. Please refer to the Member Conduct policy set forth in the Terms of Use.
   5. To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
   6. As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process, whether originating in the United States or other territory; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires immediate disclosure of communications or your Personal Information exists.
2. No Disclosure to Third Parties for Marketing Purposes Without Your Consent. We do not disclose your Personal Information to third parties for the third parties' direct marketing purposes, unless you first affirmatively agree to such disclosure.
3. Refer a Friend by Email and Sending Messages Through an Application. If you use our “Refer a Friend” feature to tell others about one of our Applications, the recipients will be sent an email inviting them to visit the Site and/or download the Application. Also, if you make available your contact information to other Users, such Users may include you within their contacts, and send you messages through an Application. Similarly, if you make available your contact information when you first register to use the Thinkster Services, other Users who know your contact information may send you messages via an Application.
4. Non-Personal Information. We may disclose Non-Personal Information for any purpose. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your unique User Device number). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

4. THIRD-PARTY SITES

In general, the Applications, the Thinkster Services and the Site access third party information through application interfaces. We may provide links to third-party websites, as a service to our Users. The Site may also carry advertisements from other companies. When you click on links of third parties in an Application, the Thinkster Services or the Site, you may leave the Application, the Thinkster Services or the Site. Some of these third party sites may be co-branded with our name/logo or our affiliated entity's name/logo, even though they are not operated or maintained by us. This Policy does not address, and we are not responsible for, the privacy practices of websites operated by third parties, whether they are linked to or otherwise accessible from an Application, the Thinkster Services or the Site. The inclusion of a link or accessibility of third party websites does not imply endorsement of such third-party website by us.

5. USERS WITH WHOM YOU SHARE YOUR INFORMATION

We cannot control the actions of other Users with whom you share your information. We cannot, and do not, control the information you share with other Users using an Application, the Thinkster Services or the Site (including via Forums) or how such other Users will use or share such information. We are not responsible for third party circumvention of our security measures.

6. CHOICES ABOUT YOUR PERSONAL INFORMATION

Opting Out of Marketing-Related Communications: You may opt out from receiving marketing-related emails, SMS, phone messages or other communications from us on a going-forward basis by contacting us at privacy@hellothinkster.com

We will try to comply with your opt-out request as soon as reasonably practicable.

Please note that if you opt out as described above, this will apply to marketing messages from us only. We will not be able to remove your Personal Information from the database of any other Users you have shared such information or from third parties to whom you have previously authorized us to share such information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request). Please also note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

Accessing, Changing or Suppressing Your Personal Information: If you would like to review, correct inaccuracies, update, suppress, delete or otherwise limit our use of your Personal Information that has been previously provided to us, you may contact us at privacy@hellothinkster.com. In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. We will try to comply with your request as soon as and to the extent reasonably practicable. Again, we cannot remove your Personal Information from the database of any other Users you have shared such information or from third parties to whom you have previously authorized us to share such information. Your device may also have settings to limit the Personal Information, including location information, provided to the Application. Review your device manual or contact the manufacturer for further information regarding these features.

We commit to investigating and resolving complaints about our collection or use of your personal information. To make a complaint, please contact our Data Protection Officer at privacy@hellothinkster.com. Please note that you may request (1) access to and rectification or erasure of personal data, (2) restriction of processing concerning the data subject to, or object to, processing and (3) portability of your data. You may also have the right to withdraw consent at any time data processing, and you may lodge a complaint about processing of your personal data with a supervisory authority. Please note, however, that your provision of data to us is a requirement necessary to enter into a contract with us.If you have questions about your Personal Information, please contact us at privacy@hellothinkster.com

Thinkster’s Use of Remarketing with Google Analytics: Thinkster collects cookies on our website to capture information about page visits. This information is anonymous and Thinkster uses this information only internally - to deliver the most effective content to our visitors. Information from the cookies is used to gauge page popularity, analyze traffic patterns on our site and guide development of other improvements to our site. Thinkster does not require that you accept cookies, however, some functionality on our website may be disabled if you decline to accept cookies. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. Thinkster never gives away information about our users. If you choose to e-mail us and provide personally identifiable information about yourself, Thinkster will use this information only to respond to your inquiry. Thinkster will not sell, rent or otherwise disclose that information to third parties unless such disclosure is necessary for the purposes set forth in this Policy, by law or a policy or notice contained or associated with a specific Thinkster product or service.

Thinkster uses analytics data and the DoubleClick cookie to serve ads based on a user's prior visits to our website. Site visitors may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or they may opt out of Google Analytics by visiting the Google Analytics opt-out page. Google has additional information available about their Remarketing Privacy Guidelines, Policies and Restrictions.

7. SECURITY

Thinkster is very concerned about safeguarding the confidentiality of your Personal Information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access and use. Please be aware that no security measures that we take to protect your information is absolutely guaranteed to avoid unauthorized access or use of your Personal Information or is impenetrable.

8. RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

9. OUR POLICY TOWARD CHILDREN UNDER 13 YEARS OF AGE

If you become aware that your child under 13 has provided us with personal information without your consent, please contact us at privacy@hellothinkster.com. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information and terminate the child's account. By using any Application, the Thinkster Services or the Site, you are representing to us that you are not under the age of 13. If you are under 13 years of age, you are not authorized to use any of the Applications and must immediately delete it from your User Devices. We recommend that minors, who are 13 years old but under 18 years old, ask their parents or legal guardians for permission before sending any information about themselves to us or anyone else, whether by using an Application, the Thinkster Services or the Site.

10. INTERNATIONAL USERS

Your Personal Information may be stored and processed in any country where we have facilities, and by using an Application, the Thinkster Services or the Site you consent to the transfer of your Personal Information to countries, including the United States, which may be outside of your country of residence and may provide for different and less stringent data protection rules than in your country. If you object to your Personal Information being transferred or used as described in this Policy, please do not use any Application, the Thinkster Services or the Site and immediately delete all Applications from your User Devices.

11. CALIFORNIA RESIDENTS

We do not disclose your Personal Information to third parties for the third parties' direct marketing purposes, unless you first affirmatively agree to that disclosure. California Civil Code Section 1798.83 permits user who are California residents to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. This law's reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. If you would like more information with respect to your privacy rights under California law, you may contact us at the contact point below. Please reference your request as “California Disclosure Information.”

12. SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships) on or through an Application, the Thinkster Services or the Site or otherwise to us.

13. CONTACTING US / REPORTING VIOLATIONS

If you have any questions or comments about this Policy or our privacy practices, or to report any violations of the TOS or abuse of an Application, the Thinkster Services or the Site, please contact us at privacy@hellothinkster.com.