Effective Date: December 31, 2018.
We do not collect or process personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or any genetic or biometric data, health-related data or data concerning your sex life or sexual orientation.
When you interact with Edwin, we call it a “lesson.” Depending upon the particular Service you select, you may communicate via text messages or chats, by submitting written or spoken content or interacting with audio or audio/video transmission and recording technologies. These communications may be with our automated Edwin bot, through our mobile applications, or with one of our human tutors or other service providers. The contents of the cumulative exchanges between you and Edwin we refer to as the “lesson content.”
We use your personal information for the following purposes:
We do not share your personal information with third parties for any purpose other than operating the Service.
Our personnel do not monitor all your lessons with Edwin, but we may review and use lesson content in order to optimize your personal learning plan and to improve our Service’s algorithms and methodology. If you elect to use part of our Service that utilizes audio or audio/video exchanges, your voice and image will be collected for use by our tutors and other personnel. We use the lesson content to assess your performance, analyze and enhance the Service’s performance, develop Service modifications, and provide support for your learning, and technical or other issues. We may use third parties to provide human tutors to work with you, depending upon the Service offering you select. We also use the lesson content with certain third-party services utilizing machine learning to analyze the lesson content and develop content for Edwin to include in lessons. We provide this lesson content to third-parties without identifying you or providing your personal information.
We use information obtained from your computing device(s), as well as information obtained from cookies, tracking pixels and similar technologies, to understand how you and other users use our Service, and to develop improvements to our Service. We may also use these technologies to help deliver promotional messages.
Our Service operates on computers owned and/or operated by Edwin and located in third-party data centers that may be located in multiple countries, including the United States. These computers store and process your personal information and the lesson content from your lessons with Edwin, using security measures commonly deployed by leading cloud service providers. If you are a resident of the European Union, you should know that we process personal information on one of three grounds, depending on the circumstances: (i) your affirmative consent, in which case you will have the right to withdraw consent at any time; (ii) contractual necessity; or (iii) our legitimate interest in providing the Service. We retain your information as long as it is necessary and relevant for the operation of our Service. After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner according to our data retention and deletion policies in effect at that time.
You determine what personal information is available to us by completing your public profile on Facebook, and by selecting different Service offerings. It is your responsibility to ensure that your information is correct in your profile, and we may rely upon that information being current. You consent to our using the then-current address(es) in your Profile to deliver notices and important messages. If you select a Service offering that includes your interaction with a human tutor, that tutor may have access to your Facebook profile information. If your personal information in your Facebook public profile has changed, you can and should correct that.
You may see your lessons and lesson content by reviewing your exchanges with Edwin in Facebook Messenger or in our mobile application (depending upon the Service you are using). We do not anticipate deleting any of the lesson content, but if Facebook purges any messages (for example, by limiting your access to messages within a certain time period), you will no longer have access to the lesson content that has been purged. You may also review your learning goal, a summary of your placement test results, a summary of your progress aggregated by week and by day for the most recent week by accessing this information via Edwin menu in Facebook Messenger.
You may ask us to change, update or fix your data that we possess if it’s inaccurate. You may request us to limit or stop using all or some of your personal data which we will do as soon as reasonably practicable, unless we determine it is necessary to provide our Service to you. You may at any time request to review any of the information that we have retained, learn how we have used it, and to whom we have disclosed it and/or request a copy of your personal data in our possession, which we will provide in machine readable form. You may also request that your personal information be deleted. If you wish to make any of these requests, please send us an email at email@example.com, and we will respond as soon as reasonably practicable. Under certain circumstances we may retain information, including personal information, if and for so long as it is necessary to provide you the Service, and after you cease using the Service if we determine it may be necessary to prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce applicable legal terms, comply with applicable legal data retention obligations and/or take other actions permitted by law.
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may contact you via Facebook Messenger, messages in our mobile application, or email with Service-related announcements that we think may be beneficial to you, and special offers. We also may contact you with information about products and services from our business partners. You may opt out of such promotional communications at any time by following the opt-out instructions. Please note that if you have agreed to receive marketing communications from any third-party service with which you are using Edwin, you must change your communication preferences with them directly. You may not opt out of receiving what we consider to be essential Service-related messages, customer services responses or other communications relating to inappropriate use of the Service or requests from third-parties to access information in your account. We may deliver those messages using any of your addresses in your profile, and may send messages to you within the Service.
We exist to provide a valuable service to you, and not to obtain your personal information to sell or rent it to third parties. The circumstances in which we disclose personal information are limited to the following:
In each of these circumstances, we try to minimize the amount of personal information we share to what is directly relevant and necessary to accomplish the specified purpose. As stated above, we do not disclose your personal information to third parties for their marketing purposes without your explicit consent.
While we use contractual and other measures to ensure protection of personal information, the laws and regulations relating to privacy and personal information protection in other jurisdictions may not be the same as, or similar to, your local privacy laws. The governments, courts, law enforcement or regulatory agencies in these other jurisdictions may be able to request disclosure of personal information through the laws of these countries. In an effort to respect your privacy, we will not otherwise disclose your personal information to law enforcement, other government officials, or other third parties without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm, financial loss or to report potentially illegal or fraudulent activity.
Some third parties’ embedded content or plugins on the Service, such as Facebook “Like” buttons, may allow their operators to learn that you have visited our website, and they may combine this information with other, identifiable information they have collected about your visits to other websites or online services.
Edwin is committed to protecting the security of your information and takes reasonable precautions to protect it. We use industry standard encryption to protect your data in transit. However, internet data transmissions cannot be guaranteed to be 100% secure, and we cannot ensure the security of information during its transmission between you and us, or our third-party service providers. Accordingly, you acknowledge that when you transport such information, you do so at your own risk.
We protect your information in our systems using technical and administrative security measures in order to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the important safeguards are digital encryption, digital and physical access controls deployed and managed by our third-party data centers and administrators, and information access authorization controls. Again, data centers and our third-party service providers are not guaranteed to be 100% secure, and so you acknowledge that your information stored in with such data centers or service providers is at your own risk.
If we learn of a system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us, by contacting you via Facebook Messenger or by posting a notice on our web site and/or via our Service and other communication platforms.
There are just a few more privacy - related details concerning your use of our Service that we wish to address:
We do not knowingly collect personal information from children, and rely upon the age limits imposed by Facebook in their account creation process. If we learn that we have inadvertently obtained information in violation of applicable laws prohibiting collection of information from children without such consent, we will promptly delete it.
We strongly encourage you to work with Edwin by yourself, and not share your access to Edwin with anyone, in order to ensure the integrity of your learning process. If, however, you wish to enable someone to have access to your Edwin account or account information after you are no longer able to provide them access, you need to implement a process for providing your account information to them. We will not provide your account information, or your lesson content, to anyone, even next of kin, unless we determine that we are legally obligated to do so.
We cannot guarantee the privacy or security of your information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of any third party before entering into a transaction and choosing to share your information.
Edwin Technology Corp.
1266 Harrison Street
San Francisco, CA 94103
Attn: Privacy Matters
Additionally, if you are a resident of the European Union and you are dissatisfied with our response to any issue you have with our Service, you may refer your complaint to JAMS, an alternative dispute resolution provider located in the United States. For more information regarding JAMS or to file a complaint directly, please visit https://www.jamsadr.com/eu-us-privacy-shield . The JAMS service will be provided to you free of charge. If you are a resident of the European Union, you may also have a right to file a complaint with your independent public authority responsible for monitoring the application of the General Data Protection Regulation.