Boluo school is a service that allows registered parents or guardians (“Parents”) to enroll learners (“Learners”) in online classes, and for registered teachers (“Teachers”) to create, publicize, and provide those classes (the “Services”). This Privacy Statement describes what personal information Boluo school collects from registered Parents, Teachers, as well as how Boluo school collects and uses personal information from visitors to our public website.
Information We Collect
When you visit our Site, we may collect information about you that, alone or in combination, could be used to identify you, your device, or household (“Personal Data”), as further described below:
Personal Data That You Provide Through the Site: We collect Personal Data from you when you directly provide it to us, such as when you register for an Boluo school account to use the Services. For example, we may collect the following Personal Data from you:
Contact Information.
· Name
· Email address
· Phone number
· Postal and billing address
Payment Information.
· Credit card or other payment information
Demographic Data.
We collect age, month and year of birth, gender, pronouns, marital status, and similar demographic details, such as when you voluntarily provide information in the “about me” section of your profile or communicate with us.
Sensitive Data.
Parents may voluntarily provide sensitive information such as health or disability information included in forms or messages sent to Teachers to aid with learning. Parents may also enroll children in special classes offered for children with disabilities. Teachers and Learners are otherwise not allowed to have discussions that may elicit or result in sharing of sensitive information.
If we suspect that a child is over 18, for safety of other Learners, we may request that a Parent show us a copy of age-identifying documentation, such as a Learner’s birth certificate, passport, or driver’s license. This documentation could show us sensitive data such as full date of birth, place of birth, and government ID numbers. Other than month and year of birth, we do not record this information.
We may also receive sensitive criminal history information about Teachers when we receive background reports.
Content and Files.
· Classes for which you have enrolled
· Video of your image and audio of your voice during classes which are automatically recorded
· Content and communications that you may include or upload like your profile photo, and photos, documents, and messages you share with the class or groups
· Your voluntarily provided profile picture
· Information voluntarily provided in the “about me” section of your profile
· Information voluntarily provided through reviews
· Information Teachers provide to let us run background checks and background check reports we receive from third parties
Passively Collected Data: When you use or interact with us through our Site, we and our third-party partners may collect, receive, and store certain data automatically. For example,
Usage data. We collect usage data (such as login times, search terms you used, and pages you viewed), and other information about your device and browser.
Identifiers and device information. We collect IP Address, device identifiers such as cookie identifiers and mobile device identifiers (see our Cookie Policy, below), your device’s operating system type, and browser type. We may use such information and pool it with other information to track usage and device and system data, for example, the total number of visitors to our Sites, the number of visitors to each page of our website, and the domain names of your Internet service providers. We and our partners may also use this data for interest-based advertising.
Inferred Data: We may infer new information from other data we collect, including using passive, automated means, to generate information about your likely interests (“inferences”). For example, we infer the class subjects your family may be interested in from searches you may perform. We may also infer your general geographic location (such as city, state, and country) based on your IP address.
Aggregated Personal Data: We may aggregate data, including Personal Data, and use such aggregated data for any purpose. This aggregate information does not identify you personally.
Required Personal Data: Some Personal Data is required such as credit card payment used by Parents to purchase classes and for verified parental consent. Teachers are also required to let us access Personal Data relating to background checks. Teachers are also required to have their cameras on while teaching a live class. Learners are required, subject to authorized exceptions, to have their video enabled at least at the start of class to verify their identity to protect the safety of other Learners. You may decline to provide certain Personal Data.
Sources of Personal Data
You are the main source of Personal Data we have about you. We may also obtain any of the above categories of information from third parties. These third-party sources include, for example:
· Third party partners. Third party applications and services, including social networks you choose to connect with or interact with through our services.
· Co-Branding/Joint Partners. Partners with which we offer co-branded services or engage in joint marketing activities.
· Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
· Publicly available sources. Public sources of information such as open government databases and background check services we used for Teachers.
Our Use of Your Personal Data
We may use any of the above categories of your Personal Data to:
· provide and enhance the Boluo school Sites, including troubleshooting, maintaining, improving, and personalizing the Sites;
· business operations, such as processing your payment for the Services, billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations;
· send you emails or newsletters that you signed up for, including messages about new and recommended classes, groups, events, and other marketing content we may send to Parents and Teachers;
· communicate with you to confirm registration and send updates, provide customers support and security alerts, and other administrative messages;
· conduct research and develop new services or features; analyze website usage and usage of the Site features, content, and pages; and
· conduct background checks if you are a Teacher.
We combine data we collect from different sources to achieve these purposes and to give you a more seamless, consistent, and personalized experience.
Teachers may access recordings of their classes and may use the recordings to improve their curriculum and classes and may provide the recording to Parents and Learners to view. Boluo school may also use class recordings to provide feedback to Teachers, for customer support, and for compliance purposes.
If you are a Parent or Teacher, Boluo school may use your contact data for marketing and advertising purposes, including to tell you about services and opportunities we believe will be of interest to you. If we do so, each promotional email we send you will contain instructions permitting you to "opt-out" of receiving future promotional information. In addition, if at any time you wish not to receive any future communications or you wish to have your contact information included in our opt-out lists, please contact us at info@boluoschool.com. Please note that we will continue to contact you via email to respond to requests and provide our services.
Storage and Transfer of Personal Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your region. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Our Disclosure of Your Personal Data
We may share your Personal Data with certain third parties with your consent or authorization and with whom you have intentionally interacted. We may share your Personal Data as necessary to complete your transactions and provide the services you have requested or authorized. For example, we use third parties to process credit card payments.
We may also share data as set forth below:
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred to a successor or affiliate alone or as part of that transaction along with other assets.
Service Providers: We engage third party service providers to perform certain functions on our behalf (such as payment processing). These third parties may have access to your Personal Data for the purpose of helping us market, provide and/or improve the Sites.
Legal Requirements: Boluo school may disclose your Personal Data if required to do so by law or when we believe that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Boluo school, Teachers, Learners, and Parents, (iii) operate and maintain the security of our Sites, including to prevent or stop an attack on our computer systems or networks, (iv) to protect the personal safety of users of the Site or the public, or (v) protect against legal liability. Teachers are required to report to Boluo school any suspected case of child abuse or neglect they become aware of during their work with Learners. Teachers may also be required to report suspected abuse or neglect to local authorities, and Boluo school expects all Teachers to comply with their individual reporting responsibilities. Boluo school itself may report instances of suspected abuse or neglect.
Third Party Analytics and Advertising Companies: Third party analytics and advertising vendors also collect Personal Data through our Site including, general location data, usage data, and inferences associated with identifiers and device information (such as cookie IDs and IP address) as described in the Cookies section of this statement. Except for data collected from Learners on the Services in Learner Space, these third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our Site to help us understand how users interact with our Site; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.
Please note that our Site includes references or links to or suggestions to engage with third parties whose privacy practices differ from ours. Teachers may also suggest third party resources for Parents and Learners. If you provide Personal Data to any of those third parties, or allow us to share Personal Data with them, that data is governed by their privacy statements.
Publicly Posted Information
You may be able to share Personal Data, including communications, with third parties, including with the general public, through use of our Site. When you do so we ask that you avoid sharing Personal Data and do not share sensitive Personal Data.
We expect everyone to respect the privacy of others and follow our community standards, and other guidelines and restrictions on posting and sharing activities, such as sharing private materials, communications, or information, or sharing other Personal Data about others that may cause harm, embarrassment, or conflict. You should not encourage your Learners or other Learners to reveal any Personal Data about Learners or their families.
User Profile: As a user of our Services, you will have a user profile that will be publicly available to all users of the Services (the “User Profile”). You are not required to include any Personal Data on your User Profile. But you will have the option to include a variety of types of Personal Data in your User Profile, which may include your first name, last name, biographical information, geographical location, and avatar or personal photograph.
Any information published in your User Profile becomes available to the public. After publishing, we have no control over how such information is used or its further dissemination. We urge you to think carefully about what, if any, Personal Data you include in your User Profile.
Online Classrooms and Pages: If you are Teachers leading our online classes, you may publicly display and share your video and photographic image, name and/or username and certain other information, such as your profile, demographic data, content and files, and general location data (such as the city or state).
Messages: Learners can message Teachers, Parents can message each other, and Parents and Teachers can message each other using the Service. Parents have access to messages between their Learners and Teachers.
After publishing, posting, or messaging, we have no control over how such information is used or its further dissemination. We urge you to think carefully about what, if any, Personal Data you share with others on our Service.
Security
We take reasonable steps to protect the Personal Data provided via the Site from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, the Internet cannot be guaranteed to be fully secure, and we cannot ensure or warrant the security of any content or information you provide to us. You are also responsible for helping to protect the security of your account credentials. For instance, never give out your password, and safeguard your username, password and personal credentials used to access the Services, so that other people will not have access to your Personal Data. And do not use the username and password you use on our Services with any other services.
Choice and Control
Browser Cookie Controls: Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
Mobile Identifier and Permission Controls: iOS and Android operating systems provide privacy options in your device settings. You can limit tracking and/or reset the advertising identifiers and change permissions regarding push notifications and access to your camera and photos.
Email Web Beacons: Most email clients have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.
Do Not Track: Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. While we do not currently support Do Not Track signals, we treat the data of everyone who comes to our site in accordance with this Privacy Statement, whatever their Do Not Track setting.
Accuracy; Correcting Personal Data.
We use reasonable efforts to keep your Personal Data accurate and up-to-date, and we will provide you with mechanisms to correct, amend, delete, or limit the use of your Personal Data. As appropriate, this amended Personal Data will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Data about you enables us to give you the best possible service.
Additional Notice for California Consumers
This portion of our Privacy Statement applies to California consumers only.
Personal Information Collected on California Consumers in the Last Twelve Months
The “Personal Information,” as defined in California Civil Code § 1798.140(o), we have obtained on California residents within the last twelve months includes the Personal Data we describe above in the Information We Collect section.
Our Use of Personal Information for Business Purposes in the Last Twelve Months
We use each category of the Personal Information we collect for the purposes disclosed within the Our Use of Your Personal Data section.
Disclosures of Personal Information on California Consumers for Business Purposes:
Within the last twelve months, we have disclosed Personal Information with limited third parties described in Our Disclosure of Your Personal Data.
California Rights and Choices
If you are a California resident, you have certain legal rights related to your Personal Information. Except as otherwise provided or excepted by applicable law, you may exercise the following rights:
A. Right to Know/Portability
You have the right to request that we disclose to you certain information about Personal Information we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:
o the categories of Personal Information we have collected about you;
o the categories of sources from which the Personal Information is collected;
o our business or commercial purpose for collecting Personal Information;
o the categories of third parties with whom we share Personal Information; and
o the specific pieces of information we have collected about you.
B. Right to Opt Out
You have a right to opt-out from future “sales” of personal information. Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing relating to cookie data and other tracking methods used for analytics and advertising purposes described in this privacy statement may be considered a “sale” under those definitions. To opt-out of this limited “sale” of personal information, please visit our Do Not Sell My Personal Information page.
We do not “sell” the Personal Information of consumers we know are less than 18 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is between 13 and 18 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt into Personal Information sales may opt out of future sales at any time.
C. Right to Deletion
You have the right to request deletion of your Personal Information that we collected from you and retain, subject to certain exceptions. Once we confirm your verifiable request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
D. Right to Non-Discrimination for Exercise of a California Privacy Rights
We will not discriminate against you because you exercise any of the above rights, or any other rights under the CCPA. Specifically, if you exercise your rights, we will not deny you access to our services, charge you different prices or rates for services or provide you a different level or quality of services.
E. How to Submit A Request
You may submit a request to exercise the rights listed above by emailing us at infoinfo@boluoschool.com. In your request, please include (1) full name used to create your account; (2) email with which you created your account; (3) phone number in case we need to contact you to securely verify your request; (4) whether you are requesting how your information is used and/or to delete your Personal Information.
F. Verifiable Request
As required under applicable law, we take steps to verify your identity before responding to your request. We may require you to provide information sufficient enough to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We may limit our response to your exercise of the above rights as permitted under applicable law.
G. Agent Authorization and Disability Access
You may designate an authorized agent to make a request on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent.
You may also make a verifiable consumer request on behalf of your minor child.
To access this Privacy Statement by an alternative method, please contact us at info@boluoschool.com.
H. Responding to Requests
We will confirm receipt of your request within 10 days from receipt and provide information about how we will process the request, our verification process, and when you can anticipate a response to the request.
We will use commercially reasonable efforts to honor your request within 45 days from receipt. If additional time is needed, we will notify you of the same, along with an explanation and anticipated timeline for the extension which shall not exceed 90 days from the date of receipt.
Other California Privacy Rights
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please send a detailed description of the specific content or information you wish to have removed to privacy@outschool.com. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
European Data Protection Rights
If our processing of Personal Data is subject to European Union data protection law, you have certain rights with respect to that data:
· You can request access to, and rectification or erasure of, Personal Data;
· If any automated processing of Personal Data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the Personal Data in a usable and portable format;
· If the processing of Personal Data is based on your consent, you can withdraw consent at any time for future processing;
· You can to object to, or obtain a restriction of, the processing of Personal Data under certain circumstances; and
· For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests or contact our Data Protection Officer, please use the contact information at the bottom of this statement. When we are processing Personal Data on behalf of another party that is the “data controller,” such as certain relationships we have with schools, you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing Personal Data about you, for example, with your consent and/or as necessary to provide the services you use, operate our Site and business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.
Retention of Personal Data
We retain Personal Data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. For example, we keep Class Recordings for 90 days after the date of the applicable Class.
Cookie Policy
What are cookies?
Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device. Cookies are used with web beacons and similar technologies. Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email and can read cookies they place on your device.
What are cookies used for?
Cookies, mobile device identifiers, and similar technologies allow a site or service to know if your computer or device has visited that site or service before. These technologies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. We and our analytics and advertising partners use cookies and other identifiers, such as IP address, and technologies on our Sites to collect Personal Data (such as the pages you visit, the links you click on, and similar usage information) when you use our Sites, including Personal Data about your online activities over time and across different websites or online services. We and our analytics and advertising partners may use cookies and similar technologies to provide targeted advertising.
How to control and review cookies
Boluo school uses third-party analytics and advertising providers on our website and in our emails. To learn more about their privacy practices and how to opt-out of their use of certain of the above cookies and other technologies for analytics and advertising on our Site and in our emails, please see our Choice and Control section and review more about our approach here.
Please note that the choices referenced in our cookie article, linked above, are specific to the browser and device you are using. If you access our Site from multiple devices or browsers, you will need to opt-out separately on those devices and browsers.
Changes to Our Privacy Statement
We may change this Privacy Statement at any time. If we decide to change this Privacy Statement in the future, we will post or provide an appropriate notice. If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law. The date on which the latest update was made is indicated at the top of this document.
Contact Us
Please feel free to contact us if you have any questions about Boluo school’s Privacy Statement or the information practices of our Sites.
You may contact us as follows: You may send an email to info@boluoschool.com
Children's Privacy Notice
This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by Learners including children under the age of 13 (“Child” or “Children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding Children’s Personal Data. For more information about COPPA and general tips about protecting Children’s online privacy, please visit OnGuard Online.
Collection: Boluo school collects Personal Data about Children directly from Parents and, when we have verified parental consent of Parents, directly from Children through our website. We may allow Children to mark Classes they like or want to attend. Parents can see marked Classes. Children can only attend Classes if their Parents enroll them. We keep a record of marked and enrolled Classes and may infer your child’s interest in topics from these records to inform recommendations and Class offerings. Parents provide us with the Child’s name and age. Parents may additionally provide us with descriptions of the type of schooling their Child attends, local time zone, and additional notes for the Teacher. In addition, Children may share information about themselves during online classes. The Boluo school Class sessions take place over online videos in which video images and audio of the Children are recorded in our systems. We may collect other Personal Data about Children in Learner Space, including passively collected data, as described in our general Privacy Notice, with the exception that we do not collect payment information from Children or allow third parties to use Personal Data collected through analytics or advertising cookies for their own purposes. We also do not condition participation in our Services for Children on the collection of more Personal Data than is reasonably necessary. Children may also share information about themselves during online classes and when reporting emergency safety and compliance issues.
Use and Disclosure: Once we obtain verified parental consent, we may use and share Personal Data collected from Children for many of the same purposes described in the general Privacy Notice. We recommend Classes, Learner Groups, and new features to Parents and Children based on Childrens’ activities on our Site, such as when they mark classes or Learner Groups or are enrolled in classes or Learner Groups and if they are using our mobile app or website. We may send these messages to Children and Parents through push notifications if Parents enable this feature in the mobile app. We may also send emails to Parents about those recommendations and surveys and informational emails to Parents and Children. We do not, however, send promotional emails to Children or allow third party analytics or advertising providers to collect Personal Data for their own uses through Learner Space.
Boluo school shares, or allows you to share, the name, age, postal address, local time zone, and any notes Parents have provided about their Child to the Class Teacher to allow the Teacher to provide Classes, facilitate Learner Groups, and deliver supplies to Children. Children can also privately message Teachers of the Classes they’re enrolled in. Parents will get notices of and copies of these messages. Children’s video image and voice audio and potentially background images of their home and family members are shared with the Teacher and the rest of the Class as they participate in Classes. Parents should consider using virtual backgrounds for their Children if they have concerns about posting images of their home and family members. Children may also share information about themselves with the Teacher and the rest of their classmates during the Class session voluntarily, including content, images, and videos they may upload and share with their Teacher and classmates. While Boluo school expects Teachers and all other Users to abide by our standards of conduct and we take reasonable steps to monitor certain communications and posts, please note that we are not able to control or monitor all Personal Data your Child may share with Teachers or other classmates, nor what those third parties ultimately do with that information.
At times, we may allow Children and Parents to submit content, including photos and artwork, along with other information about the Child (like age, first name or initials and city, state, and country) that you may allow us to display publicly. Parents should review Children’s submissions and avoid uploading any private information in the Content about the Children, family members, or others. Boluo school is not responsible for what other third parties do with information you choose to share publicly.
Some Teachers may ask Child Learners and their Parents to use third-party sites and services such as Google Class. Parents should review the privacy notices for those third party sites and services to understand their privacy practices. These third parties are not our service providers, and we are not responsible for and may not have reviewed those third-party sites and services.
Class Video Recordings: As described above, Boluo school records video of Children and Teachers during Boluo school group classes (“Class Recordings”). The Class Recordings are made available by Boluo school to the Teacher of the class and may be shared by the Teacher for the entire class (and their Parents) to view (the “Permitted Recipients”).
Boluo school will obtain additional parental consent before we use any Class Recordings for promotional or other unexpected purposes. We request that Teachers refrain from creating copies of the Class Recordings or from sharing the Class Recordings with anyone aside from Permitted Recipients, and also request that Permitted Recipients not download or re-share the Class Recordings. While we expect Teachers and Permitted Recipients to abide by our standards of conduct, please note that we cannot control or monitor what such third parties ultimately do with Class Recordings.
Parental Consent: Boluo school sends a direct notice with these privacy disclosures and obtains verifiable parental consent before collecting, using, and sharing Personal Data from your Child as described in this Notice. Boluo school requires that you provide your credit card information to verify you and to register your Child for and pay for an Boluo school Class. If you do not consent or withdraw consent, then we will not collect, use, or disclose any Personal Data about your Child, except as needed for legal compliance and enforcement purpose, and your Child will not be allowed to use the Services in any way. If you do not provide consent within a reasonable time from the date the direct notice was sent, and are not using our services for any other purposes, such as for teen children, we will also delete your online contact information from our records.
Parental Choices and Controls: At any time, you can review and refuse to permit us to collect further Personal Data from your Children in association with your account. You can also request that we delete from our records the Personal Data we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You may review and update certain of your Child’s information by logging onto your account. In your account, you can review topics of interest we have inferred based on your Child’s likes and past classes. You can choose to opt-out of recommendations based on your Child’s activities and instead choose the learning topics you want to hear about. You can contact Boluo school to request access to, change, or delete your Child’s Personal Data, or revoke consent for our collection, use, and sharing of Personal Data, by sending an email to us at info@boluoschool.com. A valid request to delete Personal Data will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete Personal Data collected from Children when it is no longer needed for the purpose for which it was collected.