COETAIL PRIVACY POLICY
This Privacy Policy was updated on May 24, 2018.
PLEASE READ THIS DOCUMENT CAREFULLY.
We at Eduro Learning, Inc. (“Eduro Learning”, “COETAIL,” “we”, “us”) respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data.
Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the COETAIL or Eduro Learning website, Learning Management System (LMS), or related services (the “Services”).
By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.
Please read this Privacy Policy carefully prior to accessing or using our website or our services. If you have any questions, please contact as at: [email protected].
What Data We May Collect
Our main purpose in collecting data from or about you is to provide you with a safe, efficient, and customized experience with our Services. We collect certain data from you directly, like information you enter yourself, data about your participation in courses, and data from third-party platforms you connect with COETAIL. We also collect some data automatically, like what parts of our Services you interact with or spend time using, and information about your device.
Personally Identifying Information (“PII”): COETAIL may collect and process information that can be directly connected with you, without the assistance of additional information; information such as your full name, username and password, email address, billing or mailing address, phone number, or credit/debit card information. You can choose not to provide us with certain information, which may result in you not being able to use certain features of our website as such information may be required in order for you to register for an account, purchase products or services, or begin other transactions on our website.
Third Party Payment Processors: Payments processed via Custom Payment Gateways by third parties like Stripe or WooCommerce are subject to the terms of privacy policies and terms of use of those payment gateways and are not accessible or controlled by COETAIL. For payments processed via Third Party Payment Processors, we receive information related to the payment status of your account; the information includes, but is not limited to, your payment card type and last four digits, payment expiration date, postal code, and country of origin. For additional information, we recommend that you review the payment processor’s Privacy Policy.
Information from Third Party Platforms: You may allow our website to interact with one or more third party social networks or platforms (such as Google or Facebook), which will give data about you to us (“Platform(s)”). The information you allow COETAIL to access varies by Platform, and it is affected by the privacy settings you and those that you are connected with establish while using such Platforms. Platforms are operated, controlled, and maintained by third parties and are not operated, controlled, or maintained by COETAIL. We suggest that you read the privacy policies and terms of use or service of those Platforms to understand how they collect and treat your data and what data they might share with us or other third parties.
Demographic and Usage Data (Non-Personal Information): COETAIL may collect data through the use of cookies, HTML5 local storage, and other similar technologies. Cookies are small text files stored by your browser as you browse the internet. They can be used to collect, store, and share data about your actions across websites, including on COETAIL. We may gather anonymous data about Users through cookie technology on an individual and aggregate level. This information is used within COETAIL internally and is only shared with third party advertisers, if any, on an aggregated or non-personally identifiable basis. You may opt out of receiving cookies from our website by following the instructions in your web browser. Deleting cookies or directing your browser to refuse them can limit your ability to use certain portions of our website that require cookies to function. COETAIL gathers certain data automatically and stores it in log files. This data may include Internet protocol (IP) addresses, browser type, operating system, and other usage information about the use of our website, including a history of the pages you view.
Non-Personal Information: Web beacons, local shared objects (“flash cookies”), or pixel tags are electronic images that allow a website to access cookies and help track general usage patterns of visitors to those websites and marketing campaigns. Web Beacons can see certain types of information, such as a description of the page where the Web Beacons are placed, time and date of a page view, and cookie numbers. No PII about you is shared with third parties with the use of Web Beacons on our website. But, with Web Beacons we may collect general information that will not personally identify you, such as: operating system, Internet browser, IP address, time of visit, date of visit, and path taken through the website. COETAIL may also collect other Non-Personal Information as visitors browse our website, such as web traffic, where visitors come from, what pages were visited, and other demographic information, such as age, gender, and search habits.
How We Use the Data We Collect
We may use the information we collect for a number of different purposes. We may use it to process transactions that you request, to maintain accounts, such as your COETAIL LMS account, to respond to your inquiries and otherwise correspond with you, to preserve the security and integrity of our website and services, and to administer, review, and/or improve the content of our website and services. We may also use the information to communicate with you, to address refunds, chargebacks, or payment disputes, or to make recommendations about courses or other services that we think may be of interest to you.
COETAIL provides to Mentors the following information about the Students enrolled in their respective Courses: (1) name, (2) email address, (3) country, and (4) the Mentor’s Course in which the Student has enrolled. COETAIL does not disclose any other information about Students to Mentors. Students assume full responsibility for use and disclosure of any other PII the Student chooses to disclose to any Mentor or other users, which at all times shall be subject to the terms of this Privacy Policy.
COETAIL may use Web Beacons internally to count visitors and recognize visitors through cookies. We may compile this Non-Personal Information to enable statistical analysis of our Services that would be used internally or with external assistance to make improvements to our website and services. We work with a number of analytics partners, including Google Analytics and Lucky Orange, who use cookies and similar technologies to help us analyze how users use the Services, including by recording the sites from which you arrive. Those service providers may either collect that data themselves or we may disclose it to them.
You can opt out of some of these services through tools like the Google Analytics Opt-out Browser Add-on and Lucky Orange Data Privacy Tool. To learn more about advertising cookies and targeting and how you can opt out, visit www.allaboutcookies.org/manage-cookies/index.html. If you’re located in the EU, visit the Your Online Choices site.
COETAIL may use and share Non-Personal Information we collect with third parties to develop and deliver targeted advertising on applications of third parties, or to analyze and report on advertising you see. We may combine Non-Personal Information we collect with additional Non-Personal Information collected from other sources. We also may share aggregated, non-personal information, or personal information in non-human readable form, with third parties, including advertisers and advisors. For more information regarding your choices about how third parties collect information about you on our website see the Do-Not-Track Procedures section below.
COETAIL may disclose any of your information, except as stated above, which in some cases includes PII, in the following situations:
- With our authorized service providers. COETAIL may share your PII with our authorized service providers that perform certain services on our behalf. These services may include supporting our website functionality, performing business and sales analysis, processing credit card payments, and supporting other features offered through our website. These service providers may have access to PII needed to perform their functions but are not permitted to use or share such information for any other purposes.
With your consent. COETAIL may transmit your PII to a third party when you give us express permission to do so. For example, this can occur if we complete a transaction at your request or on your behalf. - COETAIL may use information available on the availability and performance of COETAIL powered websites for advertising purposes on coetail.com, and external outlets. Additionally, COETAIL may use the information available within a Student’s LMS account for promotional activities unless and until the Student informs us that they no longer wish to receive any promotional materials.
- In connection with a substantial corporate transaction, such as the sale of our business; a consolidation, merger, divestiture, or asset sale; or in the event of bankruptcy. If another company acquires COETAIL, that company will take on all responsibility for the information we collect, including PII, and it will assume all rights and obligations with respect to that information. Should this happen, the acquiring company may implement its own policies with respect to your information.
- If we are required to disclose information by law. COETAIL may be obligated to disclose a User’s personal information, if directed by a court of law or other governmental entity. Without limiting the foregoing, we reserve the right to disclose such information where we have a good faith basis to believe that such action is necessary to: (a) comply with the law; (b) protect and defend COETAIL’s rights and property, or safety of COETAIL, our users, our employees, or others; (c) protect against misuse or unauthorized use of our website and/or Services and/or to enforce our Terms of Use or other agreements or policies; and/or (d) protect your personal safety or property or that of the public. In the event that your information is disclosed, we will comply with the law and make commercially reasonable efforts to notify you.
- Keep in mind that all of the information that you disclose or content that you post in your user profile, forum posts, comments, or other public portions of our website becomes public information. Because this information is publicly available, we cannot control how others treat it so we ask all Users to exercise care in deciding what information they chose to share. If you terminate your COETAIL account, we may retain your PII for administrative purposes but will not publicly or share it in any other way. This does not mean that we will remove your posts from our publicly available information.
New Uses of Information
At times, we may use visitor information for new, unexpected uses not previously disclosed in our Privacy Policy. If our information operations change at some time in the future, we will post the policy changes to our website to notify you of these changes. If you have concerns about how your information is used, you should visit our website periodically and review our policies.
Data Retention
We will retain your data for a period of up to three (3) months (or the maximum time required by law) after your account (a) has been cancelled, or (b) is on a credit hold for nonpayment.. After this time, the information will be permanently removed from our servers and no one will be able to access it. Your personal information such as your email, name, type of account you had, and payment history will remain on file for a period of up to ten (10) years, or the maximum time required by law, to comply with government regulations. Again, this does not mean that we will erase your posts from our publicly available information.
Access to Your Information
COETAIL will provide you with access to PII that you submitted to COETAIL for as long as we preserve that information in a readily accessible format. If you believe that any PII we are holding is incorrect or incomplete, or to have COETAIL completely remove your PII from our systems, please send an email with your specific request to [email protected]. We will work with you to make any corrections deemed necessary. We may not comply to a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In addition, note that registered Mentors and Students may change appearance of their individual information throughout our website by editing their personal profiles.
If you provide your email address to COETAIL, you will always have the right to opt out of receiving email newsletters and promotions through the unsubscribe link in the email communications. COETAIL may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without allowing you the opportunity to opt out of receiving them. It is important to note that changing information within your account, or otherwise opting out of receipt of promotional email communications will only affect future happenings or communications from us.
Our Policy Concerning Children
As stated in our Terms of Use, our website and services are offered and available only to you if are 18 years or older, or if you are between 13 and 18 years old and have obtained the consent of a parent or legal guardian prior to accessing the website, registering an account, or using the services. If you do not meet this eligibility requirement, you may not use our website or services. COETAIL does not knowingly collect or store any personal information from or about children under the age of 13. We will delete such information if we become aware that it has been submitted through our website. Parents or legal guardians who believe that COETAIL might have any information from or about a child under the age of 13 may submit a request to [email protected] and request that such information be removed.
Securing Your Information
COETAIL uses a variety of security measures designed to protect your PII and keep it confidential (unless it is non-confidential by nature) and free from any unauthorized modification. For example, only authorized employees are allowed to access personal information, and they may do so only for pertinent business functions. Additionally, we use encryption in the distribution of financial information between your system and ours, and we use firewalls to help prevent unauthorized persons from obtaining access to your personal information.
Where COETAIL has given you (or where you have selected) a password for access to certain areas of our website, you are responsible for keeping this password secure and confidential. The safety and security of your information also depends on the precautions you take, we ask that you not share your password with anyone.
Third Parties and Other Information Collectors
Aside from otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the amount that you disclose your information to other parties through our website, whether between Mentor and Student or other Users or individuals, different rules may apply to their use, collection, and disclosure of the personal information you disclose to them. Since we do not control the information use, collection, or disclosure policies of third parties, you are subject to their privacy policies.
The COETAIL website may include links to third party websites. You should note, we do not have any control over third party websites. Once you have used these links we are not responsible for the content of such websites or the protection and privacy of any information which you provide while visiting such sites. Third-party websites are not regulated by this Privacy Policy. It is important that you exercise caution and look at the privacy policies relevant to the websites in question.
Do-Not-Track Procedures
Please note, that any Do-Not-Track instructions from your browser or similar system will not affect our collection of the data that you voluntarily distribute to COETAIL through such means as browsing our website, signing up for any of the Courses or Services, entering PII into information fields on our website, or posting on any of our forums or blogs. Be aware that third parties are free to collect any information that you offer to COETAIL that is visible to the public. For that reason, please do not provide COETAIL with any information that you do not want collected.
California Civil Code Section 1798.83 Compliance
Under California law, upon request COETAIL is required to disclose to its California customers the identity of any third parties to whom we have disclosed PII within the previous calendar year, along with the type of PII disclosed, for the third parties’ direct marketing purposes. Please note that under California law, we are only required to respond to a customer request once during any calendar year. If you are a California resident and would like to make such a request, email us at [email protected].
Users Outside of the United States
COETAIL Sites are hosted in the United States and are governed by the laws of the United States. If at anytime you are using the Sites outside the United States, be cognizant that your information will be transferred to, stored, and processed in the United States where COETAIL’s servers and databases are located. By using the COETAIL Sites, you authorize the transfer of information to countries outside your country of residence.
No Rights of Third Parties
This Privacy Policy does not produce rights enforceable by third parties or require disclosure of any personal information relating to users of the website.
Changes to the Privacy Policy
We may review and revise this Privacy Policy from time to time per our discretion. It is the responsibility of Users to keep acquainted of those changes. All changes are effective immediately when posted. Your continued use of the Sites or Services after COETAIL makes changes to this Privacy Policy is considered to be acceptance of those changes. Please check this webpage periodically for updates. In addition, COETAIL will notify Users of any perceptible or significant changes to this Privacy Policy relating to the way in which we use your personal information by placing a notice on the Sites and notifying registered Users via email.
Contact Us
If you have questions or concerns regarding this Privacy Policy, you may contact us at: [email protected].