Privacy policy

Effective Date: December 31, 2018.

This Privacy Policy describes how Edwin Technology Corp. collects, uses and protects your information when you use the Edwin private tutoring service or interact with us through our websites, mobile applications, tools and associated services (collectively, our "Service"). Depending upon how you use our Service, certain portions of this Privacy Policy will not apply. For example, if you only use our iOS application, references to your Facebook profile or our automated bot will not apply.

Collecting Information

Personal Information

In order to provide personalized experience and deliver the Service, we collect a variety of personal information. When we refer to "personal information" in this Privacy Policy, we mean information that can be associated with a specific person and could be used to identify that person either from that data alone or from that data in combination with other information that we have or likely have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person. The personal information we collect includes, but is not limited to, the following:

  • information from your Facebook public profile, which may include name, image, email address, gender, birthday, and current city;
  • information you include in message exchanges with Edwin during a “lesson” (as we describe below), which may, if you elect to take a course with a human teacher, include audio and/or video recording of you and your communications with our personnel;
  • information automatically collected by our Service, such as your IP address and the type of device and browser you are using;
  • information you provide in connection with any customer support, product evaluation, product or service improvement, dispute resolution and other communications with our Service and personnel;
  • information collected by cookies, web beacons and other technologies; and
  • information regarding the geographic location where your computing device is located when interacting with our Service.

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.”

Content from Facebook

Edwin sometimes operates as a bot on the Facebook Messenger platform. As indicated above, we obtain information included in your public profile and we obtain the lesson content generated when you interact with Edwin. We use this information solely to enable us to provide our Service to you and to improve our Service. The information that Facebook provides or makes available to us may change from time to time, so please carefully review the Facebook Data Policy and your terms of use to ensure you understand, and are comfortable, with the information you provide to Facebook and which, in turn, may be available to us.

Other Automatically Collected Information

We use cookies, tracking pixels and similar technologies on our Service to collect information that helps us provide our Service to you, and to learn how our Service is used. Cookies are small text files sent by us to your computer and from your computer to us, each time you visit our website. They are unique to your Edwin account or your browser. Edwin sets and accesses our own cookies on our company-owned domains. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.

We use cookies in the following ways:

  • To enable our service to function properly. These cookies do not track your browsing activity on non-Edwin websites and products.
  • To understand how you use our Service through commonly available analytics packages. By providing us with information about how you interact with our website and products, these tools help us learn how to make your experience even better. For example, Google Analytics uses cookies to help us see how successful certain features and functionality are. You may opt-out of third party cookies from Google Analytics on its website.

Using information

Personal Information

We use your personal information for the following purposes:

  • to establish your account with our Service, and to communicate with you regarding your account;
  • to operate, improve and personalize our Service for you;
  • to provide you information regarding our Service and other services or products, or redeem promotional offers (consistent with your communications preferences);
  • to display in your user profile; and
  • to contact you to detect, prevent and mitigate fraudulent or illegal activities, investigate or inform about any security issues, enforce our agreements with you or other applicable policies, and comply with our legal obligations.

We do not share your personal information with third parties for any purpose other than operating the Service.

Lesson Content

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.

Information Obtained via Technical Tools

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.

Managing Information

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.

Your choices and right to access information

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.

Lesson Content

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. 

Managing, Reviewing and Deleting Data

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, 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.

Communication Preferences

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.

Disclosing information

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:

  • We have your explicit consent to share the information.
  • We need to share your information with service providers who process data on our behalf in order to operate and improve the features and functionality of the Service; process your payment transactions; fulfill your Service requests; and help us communicate with you as described elsewhere in this Privacy Policy; these providers are subject to strict data protection requirements.
  • We believe it is necessary to investigate potential violations or enforce the terms of applicable legal agreements, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud or potential threats against persons, property or the systems on which we operate the Service.
  • We determine that the access, preservation or disclosure of information is required or permitted by law to protect the rights, property or personal safety of Edwin and users of the Service, or is required to comply with applicable laws, including compliance with warrants, court orders, subpoenas, legal process, or other lawful government requests (including in response to public authorities to meet national security or law enforcement requirements).
  • We do so in connection with the sale or reorganization of all or part of our business, as permitted by applicable law.

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.

Securing your information

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.

Service related details

There are just a few more privacy - related details concerning your use of our Service that we wish to address:

Information from Children

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.

Sharing With Others

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.

Third Party Privacy Practices

This Privacy Policy addresses only the use and disclosure of information we collect from you and in operating our Service. If you disclose your information to others using a third-party service, their privacy notices and practices will apply. For example, when you communicate with Edwin using Facebook Messenger, Facebook’s Data Policy governs certain elements of your communications.

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.

Scope of policy

This Privacy Policy describes your privacy rights when you elect to use our Service, and by using our Service or engaging with us, you accept the substance and application of these terms and policies, and consent to our collection, use, disclosure and retention of your personal information as described in this Privacy Policy. Should you ever disagree with this Privacy Policy, please provide us with your feedback at, but if you elect to use any of our Service, you are confirming your acceptance of these terms. Edwin Technology Corp. is the data controller and processor for the Service, and we may store and process your personal information on computers in the US and elsewhere in the world where our data centers are located.

Changes to policy

A variety of factors may require changes to this Privacy Policy, including the evolution of our Service and changes in laws applicable to us. We will publish an announcement and effective date of any change, along with a description of any material change, at our Changes to Edwin Legal Documents page, and may elect in some cases to send you a message alerting you to the change. As long as you continue to use the Service, you are bound by the terms of the Privacy Policy. If you disagree with any changes and do not wish your information to be subject to a revised Privacy Policy, you will need to close your account and/or stop using the Service.

Questions or Concerns

If you have questions or concerns about this Privacy Policy or information handling processes, you may contact us at the following addresses:
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 . 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.