We at Shafsal Solutions, Inc., a California corporation, and its affiliates ("Shafsal Solutions", "we", or "us"), have created this Privacy Policy to describe our practices regarding information we collect through the Studymile app (the "App"), as well as any information we collect offline and combine in our databases. This Privacy Policy was last updated on August 12, 2014.

Summary

This summary provides an overview of some important information regarding our use and sharing of your information, but please review our full Privacy Policy before using the App.

We primarily use the information we collect when you use the App so that you can effectively use the App and for sending you information from us or on behalf of certain third parties. This includes linking you to other members of the Studymile community, and, in some cases, may allow you to engage in real-time communications with other users. It also includes providing offers to you based on information you provide or we collect or your use of the App. Please note that if you create a user profile, some of your information may be public. We do not share your Personal Information with third parties for their marketing purposes without your consent; however, we may share your Personal Information under certain limited circumstances.

Shafsal Solutions may work with network advertisers, ad agencies, analytics service providers and other vendors to serve third party advertisements on and through the App, to provide us with information regarding traffic on the App, including the actions users take when visiting the App; and to provide us with information regarding the use of the App and the effectiveness of any advertisements. For example, if you click on an advertisement, our service providers may be able to tell us the advertisement you clicked on and where you were viewing the advertisement. Advertisements within the App may be served by one or more third parties, who may use information about your activities on the App to provide you targeted advertising based upon your interests. Our ad network providers, the advertisers, ad agencies, analytics service providers and other vendors may set and access their own tracking devices and they may otherwise collect or have access to information about you and your visits to and activity on the App.

INFORMATION WE COLLECT

Registration and Other Information You Provide

The App may collect "Personal Information" (i.e. information that can be used to identify or contact a specific individual, such as your name or email address), account information (such as a password or other information that helps us confirm that it is you accessing your account) and demographic or other information (such as your school, gender, age / birth date and zip code). We, or our third party payment processor, also may collect payment information (typically, credit card account information) if you choose to purchase products or services through the App. If you use the App to offer your own products or services for sale (e.g., registering as a tutor) or in any other manner that may necessitate payment to you, we, or our third party payment processor, may collect additional information from you, such as your Social Security Number or taxpayer identification number, as necessary to facilitate payment and to comply with related legal obligations. Any information combined with Personal Information will be treated as Personal Information.

Your Profile and User Content

You may have the opportunity to create a profile, which consists of information about you, which may include Personal Information, information about your academic and work history, your interests and activities, your use of the App and other information ("Profile"). Some of the information in your Profile may be visible to third parties, depending on the nature of the information and your privacy settings for your account. Shafsal Solutions may also make the information contained in your Profile accessible through means other than the App (such as through a website or an application programming interface (API)).

Note that in order to provide services and opportunities to you, third parties may be able to review certain information in your Profile, whether or not you have limited public access to that information. You may have the opportunity to control whether this information is shared, but some information may be shared automatically -- all as disclosed on the App. Shafsal Solutions does not share your contact information (email, full postal address or phone number) with those third parties unless you request or agree to that sharing. However, Shafsal Solutions may send you information and offers from third parties and information about the App, and you may not be able to opt-out from these messages without closing your account.

The App may provide you the opportunity to participate and post content publicly in forums or virtual study groups, through interactive features and through other communication functionality ("Community Forums"). You may choose, through such features or otherwise, to submit or post reviews, problems, suggestions, ideas, solutions, questions, answers, comments, testimonials, feedback, messages, images, videos, text or other material ("User Content"). Your User Content may also be posted in your Profile. Please think carefully about what you post and before including Personal Information in your User Content. You may edit or remove your Profile information, but you may not be able to remove answers or postings or other uploaded User Content. To request removal of content you posted publicly on the App, contact us at customerservice@shafsal.com. We will honor removal requests received from registered users who are minor residents of California, unless otherwise excepted by law, and where otherwise required by law. Other removal requests received, may, in our sole discretion, be honored or refused. In some cases, we may remove only your Personal Information but maintain the rest of your User Content. Note that removal of public postings does not ensure complete or comprehensive removal of the content or information posted.

Note that anything you post to a Community Forum may be public. If you choose to voluntarily disclose Personal Information in your Profile or a Community Forum, that information will be considered public information and the protections of this Privacy Policy will not apply.

In addition, the App may allow members to communicate and collaborate with each other, including allowing members to engage in one-on-one communication or virtual study groups. If you create an account, participate in a Community Forum or choose to communicate with others through the App, certain information about you may be disclosed in connection with your or others use of the App, including certain information about you and your network. Our servers may record and we may retain records of the content of any such user-to-user communications.

We allow other users to use contact information they have about you, such as your email address, to find you.

You and Your Parents Control Your Personal Information

You can visit your Profile anytime to see Personal Information we have collected about you, and you can tell us if you want to receive any promotional mail or email from us.

NOTICE TO ALL CHILDREN

Never provide any information about yourself on the App without your parent's/guardian's permission. Read the Parental Consent Policy below with your parents/guardians before using the App. Shafsal Solutions requires your parents'/guardians written permission for children under the age of 13 to provide us with Personal Information.

PARENTAL CONSENT POLICY

Shafsal Solutions is committed to protecting the online privacy of children. In accordance with the Children's Online Privacy Protection Act (COPPA), Shafsal Solutions will not knowingly collect any Personal Information from children under the age of 13 without first obtaining parental consent.

IMPORTANT NOTICE TO CHILDREN UNDER THE AGE OF 13

A. Requirement for Submitting Parental Consent Form Before Use of the App. Prior to providing any personally identifiable information (your name, email address, address, phone number etc.), either by placing setting up an account or participating in any other activity offered through the App, children under the age of 13 must have a parent or legal guardian complete and return (by mail, email or fax) a parental consent form to Shafsal Solutions, Inc., 35 Night Heron Aliso Viejo, CA 92656; by email to: customerservice@shafsal.com. The consent form must state that the child's parent or legal guardian, by his or her signature, consents to the collection and transfer of the child's personally identifiable information. Consent may be revoked by completing a revocation of parental consent form and sending it to the address, email address or fax number above.

B. Use of Web Site and Collection and Use of Information After Parental Consent Given. If parental consent has been given, Shafsal Solutions will only collect and use personal information (e.g., email address, mailing address, payment method and details) to the extent necessary to administer the requested activity. Information collected may also be used by Shafsal Solutions for internal review purposes in aggregate.

C. Parental Monitoring. Shafsal Solutions recommends that parents/guardians monitor and supervise the online activities of their children.

NOTICE TO PARENTS

It is important for you to talk with your child about using the Internet and mobile applications safely. Here are just a few things to keep in mind when talking to your kids about the Internet and mobile applications:

          Remind your child to never give out his or her full name, address, or phone number without your permission.

          Tell your child that if he or she receives something that he or she is not sure about, to let you know.

          Impress upon your child the importance of never engaging others in a communication that would put him or her at risk, such as agreeing to meet someone he or she has been "chatting" with, but never met.

We will not condition a child's participation in a certain activity on the App on the child's providing more personal information than is necessary in order to allow such participation.

Note to parents of children under the age of 13: You are welcome to contact us at the email address above to review any identifiable information we have collected about your child. If you desire, you may request that we delete this information or specify that we collect no more of your child's information. Please note that we will need to verify the identity of anyone requesting information about a child to ensure that the person is in fact the child's parent or legal guardian, and that a request for us to delete all personal information about a child requires us to cancel the child's account.

Information We Collect Automatically When You Access The App

Like other apps, we and our analytics providers and other third party service providers may automatically collect certain "Usage Information" whenever you access and use the App.

Usage Information may include all of the areas within our App that you visit (including information about any ads you may view), and the time of day you used the App, among other information. We may use Usage Information for a variety of purposes, including to notify you of people or events nearby, to provide special offers, to serve advertisements, to select content to display to you, and to enhance or otherwise improve the App and our products.

In addition, we automatically collect your unique identifier ("Device Identifier") for any device (any, a "Device") you may use to access the App. A Device Identifier is a number that is automatically assigned to your Device used to access a App, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the Device used to access the App. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.

Usage Information is collected via tracking technologies, including embedded scripts, which is programming code that is designed to collect information about your interactions with the App, such as the links you click on. The code is temporarily downloaded onto your Device from our server or a third party service provider and is deactivated or deleted when you disconnect from the App. In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.  

HOW WE USE YOUR INFORMATION

We use the information you provide in your Profile (including Personal Information), User Content, and Usage Information to: (1) allow you to participate in features we offer or to respond to your questions, complaints or comments; (2) tailor content, recommendations and offers we display to you; (3) process a transaction you initiate; (4) send or display to you and others using the App special offers or advertisements from us, our advertisers, or third parties; (5) process your registration, including verifying your e-mail address is active and valid; (6) improve the App and our products; (7) contact you regarding your use of the App and, in our discretion, changes to our policies; (8) permit other users to contact you, and vice versa; (9) provide you with location features and services (e.g., telling you about local deals and events); and (10) for purposes disclosed at the time you provide your information or otherwise with your consent.

Note that we may create, facilitate or display social advertisements, whereby your name may be used to advertise products and services to you based on your use of the App (a Social Ad). If we are utilizing Social Ads on the App, you will be able to opt-out through your account settings.

SHARING OF YOUR INFORMATION

Shafsal Solutions does not share your Personal Information with third parties for their marketing purposes without your consent. Shafsal Solutions may share non-Personal Information, such as aggregate user statistics, demographic information and Usage Information with third parties, including advertisers, content providers, and analytics providers; and third parties may collect non-Personal Information when you visit the App. We also may share your Personal Information with third parties with your consent, as disclosed at the time you provide us with information, and as described below or otherwise in this Privacy Policy:

1. When You Request That We Share Your Information. We may offer opportunities and features through the App that are brought to you by a third party or that otherwise involve sharing your information with a third party. If you request or agree at that time to have your information shared, your information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. You also may request, sometimes through your use of an interactive feature, a widget or third party application, that we share information about you with a third party and we will typically do so under those circumstances.

2. App Providers. We will share your Personal Information with third parties to provide services to us or you in connection with the App, but subject to confidentiality obligations which limit their use and disclosure of such information. If you purchase any products or services, our billing partner will receive billing and financial information (e.g., credit card numbers) necessary to process your charges, including your postal and e-mail addresses, depending on your payment method.

3. Administrative, Legal Reasons & Academic Integrity Investigations. We may also disclose your information, including Personal Information, in response to a subpoena or when required by law; to defend our rights; in response to a written request from law enforcement regarding an investigation into criminal activity that may have occurred through or in any way using the App; to provide information to a claimed owner of intellectual property who claims that content you have provided to us infringes on their rights; upon request of an academic institution connected to an investigation into academic integrity; to protect or defend any applicable Terms of Use or other policies applicable to the App; or to protect the personal safety, rights, property or security of any organization or individual. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. These disclosures may be carried out without notice to you.

4. Business Transitions Shafsal Solutions may share Personal Information with its parent, subsidiaries and affiliates, primarily for business and operational purposes. In the event that Shafsal Solutions goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, or other corporate change, including, without limitation, during the course of any due diligence process, your information, including Personal Information, will likely be among the assets transferred. You will be notified via email and/or a prominent notice on the App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. This Privacy Policy will become binding upon the new owner of the information until amended.

THIRD PARTY AD NETWORKS AND ANALYTICS PROVIDERS

Shafsal Solutions works with network advertisers, ad agencies, analytics service providers and other vendors to serve third party advertisements on and through the App; to provide us with information regarding traffic on the App, including the actions users take when using the App; to serve our advertisements on websites, within mobile apps, and elsewhere online; and to provide us with information regarding the use of the App and the effectiveness of our advertisements. For example, if you click on an advertisement, our service providers may be able to tell us the advertisement you clicked on and where you were viewing the advertisement; likewise, if you click on an ad you see on our App, our service providers may be able to tell which page you were visiting on the App and pass that information to the advertiser. The advertisements you see may be served by one or more third parties, who may use information collected over time about your activities on the App, and other web sites and services, to provide you targeted advertising based upon your interests.

We may share Usage Information about visitors with third party advertising companies, analytics providers and other vendors.

MOBILE USE

If you use the App through a mobile device, your mobile Device Identifier, your mobile carrier, and your physical (GPS) location may be transmitted to Shafsal Solutions. You agree that Shafsal Solutions may store and use that information for security purposes (for example, for user verification and to ensure that Shafsal Solutions's APIs are being used appropriately) and, if available, for purposes of assisting you in locating nearby shipping stores, schools, restaurants, or other places of interest. If you wish to no longer allow Shafsal Solutions to track your physical locations you may turn this off within your device settings. You may be able to opt-in to receiving text messages from Shafsal Solutions. You may always opt-out by replying "STOP" to one of the text messages received. You also acknowledge and agree that use of the App through a mobile device may cause data to be displayed on and through your mobile device which may be viewed by your mobile carrier or other access provider.

CLOSING YOUR ACCOUNT

If you wish to close your account, please send your request to customerservice@shafsal.com subject line:close account and we will remove your Personal Information and Profile, if applicable, from the active databases for the App.  Even if your account is closed, information may remain in backup records and we may retain certain data if it may be necessary to prevent fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery or if required by law. All retained data will continue to be subject to the Privacy Policy. Also, if you have posted content on or through the App, such as in Community Forums, we may not be able to delete it.

THIRD PARTY CONTENT

Certain content provided through the App may be hosted and served by third parties, which may include third party widgets. In addition, the App may link to third party content over which Shafsal Solutions has no control and which are governed by the privacy policies and business practices of those third parties.

SECURITY

Shafsal Solutions takes commercially reasonable security measures to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, as in any real-life scenario, we cannot guarantee its absolute security. If you have any questions about security on our App, you can email us at customerservice@shafsal.com  subject line: security.

CONSENT TO TRANSFER

The App is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the App, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.

CHANGES TO THIS PRIVACY POLICY

Shafsal Solutions may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your Personal Information, we will display a notice through the App prior to the change becoming effective. We may also notify you by email. However, we will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code 1798.83 permits our visitors who are California residents to request certain information regarding their disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please by one of the means set forth in the Questions or Comments section below.

QUESTIONS OR COMMENTS

If you have questions or comments about this privacy policy, please contact us as follows:

Email:     customerservice@shafsal.com

Mail:        Shafsal Solutions, Inc.

Attn: Privacy Policy Issues

35 Night Heron

Aliso Viejo CA 92656