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Privacy Policy

GapSquad Inc. ("GapSquad," "we," "our," and/or "us") values the privacy of individuals who use our website, app, and related online services (collectively, our "Services"). This privacy policy (the "Privacy Policy") explains how we collect, use, and share information from users of our Services ("Users", "you", and/or "your") It applies to our student customers ("Students"), and individuals who teach courses through our Service ("Instructors"). By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

INFORMATION WE COLLECT
We may collect a variety of information from or about you or your devices from various sources, as described below.

Information You Provide to Us
  • Registration and Profile Information. When you sign up for an account, we ask you for contact information such as your name, email address, phone number, and address. We may also ask you for information such as your job title, company, and date of birth. If you sign up using a third-party account such as a social media account, we will receive similar information from those services and may receive additional information such as profile photo and connections.
  • Application and Enrollment Information. As part of our application or course enrollment process, we and the instructors offering the course will collect additional information about you such as your professional history, educational history, individual preferences, and demographic information. This information may be used to create your profile on the Services.
  • Communications. If you contact us directly, we may receive additional information about you. For example, if you contact us for customer support, we may receive your name, email address, phone number, the contents of the message and any attachments you send to us, and any other information you choose to provide. If you subscribe to our newsletter, we will collect certain information from you, such as your email address.
  • Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.
  • Payment Information. If you make a purchase through our Services, your payment-related information, such as credit card or other financial information, is collected by our third party payment processor on our behalf.
  • Ratings and Feedback. If you choose to rate and/or provide feedback through our Services, we will receive any information and content you choose to provide to us.
Information We Collect When You Use Our Services
  • Video and Audio Recordings. When you attend online classes, these sessions may be recorded.
  • Location Information. When you use our Services, we receive your precise location information. We also infer your general location information, for example, by using your internet protocol (IP) address.
  • User Content. As part of our Services, users can upload audio, videos, comments, and other content directly to our Services or through integrations with third-party technologies. We will receive all information our users choose to upload.
  • Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, such as the pages or other content you view, the searches you conduct, people you follow, purchases you make, and the dates and times of your visits.
  • Device Information. We receive information about the device and software you use to access our Services, such as your IP address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.
  • Information from Cookies and Similar Technologies. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. We and third party partners collect information using cookies, pixel tags, or similar technologies (collectively “cookies”). We and our third party partners, such as analytics and advertising partners, may use the following cookies to collect information about your online activities over time and across different services:
    • Strictly necessary cookies. Some cookies are strictly necessary to make our Services available to you; for example, to perform your login functionality and for user authentication and security. We cannot provide you with the Services without this type of cookies.
    • Functional cookies. These are used to recognize you when you return to our Services. This enables us to personalize our content for you, greet you by your name and remember your account preferences.
    • Analytical or performance cookies. These are used in order to operate, maintain and improve our Services. We use third party analytics providers such as Google Analytics. Google Analytics uses first-party cookies to track user interactions which helps show how users use our Services. This information is used to compile reports and to help us improve our Services. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you use our Services by going to https://tools.google.com/dlpage/gaoptout or via Google’s Ads settings.
    • Marketing cookies. We also use cookies to provide customized advertisements, content and information to you on our Services and other websites. We will use third party marketing cookie providers, such as Google Ads, to help us tailor your advertisements.
    Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. Where required by applicable law, you will be asked to consent to certain cookies before we use or install them on your computer or other device.
Information We Receive from Third Parties
  • Information from third party services. If you choose to link our Services to a third party account, we may receive information about you, including your profile information and your photo, and your use of the third party account. If you wish to limit the information available to us, you should visit the privacy settings of your third party accounts to learn about your options.
  • Other third parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you.
HOW WE USE THE INFORMATION WE COLLECT
We may use the information we collect:
  • To provide, maintain, improve, and enhance our Services;
  • To personalize your experience on our Services such as by providing tailored content and recommendations;
  • To understand and analyze how you use our Services and develop new products, services, features, and functionality;
  • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
  • For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
  • To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports;
  • To send you text messages and push notifications;
  • To facilitate transactions and payments;
  • To find and prevent fraud, and respond to trust and safety issues that may arise;
  • For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
  • For other purposes for which we provide specific notice at the time the information is collected.
LEGAL BASIS FOR PROCESSING EUROPEAN PERSONAL INFORMATION
If you are located in the EEA or the UK, we only process your personal information when we have a valid “legal basis”, including when:
  • Consent. You have consented to the use of your personal information, for example to use cookies.
  • Contractual necessity. We need your personal information to provide you with the Services, for example to respond to your inquiries.
  • Compliance with a legal obligation. We have a legal obligation to use your personal information, for example to comply with tax and accounting obligations.
  • Legitimate interests. We or a third party have a legitimate interest in using your personal information. In particular, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your personal information when these interests are not overridden by your rights and interests.
HOW WE SHARE THE INFORMATION WE COLLECT
  • Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.
  • Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.
  • Instructors and Educational Institutions. We share student information with your Instructors and institutions they may be affiliated with, including registration and enrollment information.
  • User Content. Our Services are designed to be a collaborative learning experience. Your name and other profile information may be viewable and searchable by other users. The content you post to the Services will be displayed on the Services and may be viewable by other users. We are not responsible for the other users’ use of available information, so you should carefully consider whether and what to post or how you identify yourself on the Services.
  • Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.
  • Advertising Partners. We work with third party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
  • As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.
  • Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.
  • Consent. We may also disclose your information with your permission.
YOUR CHOICES RIGHTS AND CHOICES
  • Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
  • Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
  • Your European Privacy Rights. If you are located in the EEA or the UK, you have the additional rights described below:
    • You may request access to the personal information we maintain about you, update and correct inaccuracies in your personal information, restrict or object to the processing of your personal information, have the personal information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your personal information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
    • You may withdraw any consent you previously provided to us regarding the processing of your personal information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
    You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. Before meeting your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
THIRD PARTIES
Our Services may contain links and integrations to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

RETENTION
When required by law, we take measures to delete your personal information or keep it in a form that does not permit identifying you when this personal information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this personal information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

SECURITY
We make reasonable efforts to protect your information by using safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

INTERNATIONAL TRANSFERS
Our services are hosted in the United States. If you choose to use our Services from the EEA, the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. When we do so, we shall ensure that relevant safeguards are in place to afford adequate protection for your personal information. If you are located in the EEA or UK, please note that we may transfer your personal information to countries that have been found to provide adequate protection according to the competent authorities (such as the European Commission), use contractual protections for the transfer of personal information, transfer to recipients who have adopted Binding Corporate Rules, or rely on a derogation from data transfer rules in a specific situation. Further details regarding the relevant safeguards can be obtained from us on request.

CHILDREN
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].

ACCESSING/UPDATING YOUR INFORMATION
You can update your account and profile information through your profile settings.

CHANGES TO THIS PRIVACY POLICY
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

CONTACT US
If you have any questions, comments, or concerns about our processing activities, please email us at [email protected].
  
© 2023 GAPSQUAD, INC.
 
 

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