PLEASE READ THIS POLICY CAREFULLY. IT DESCRIBES HOW BESPOKE EDUCATION, INC. COLLECTS, USES AND MAINTAINS PERSONAL INFORMATION SHARED OR OTHERWISE OBTAINED IN CONNECTION WITH USING WWW.BESPOKEEDUCATION.COM AND RELATED SITES
This Policy was last updated on August 31, 2021
This Policy applies only to information collected through our Sites and not to information we may collect from you offline. This Policy should be read in conjunction with our User Agreement, which can be accessed at the bottom of our main website page and further defines the terms pursuant to which you may access and use our Sites and our Services.
2. Personal Information: “Personal information” means any information relating to your registration and use of our Sites or our Services that specifically identifies you or your account, which might include items such as your full name, email address(es), mailing address, phone number(s) and, if applicable, credit card number(s). We collect personal information whenever you send us an inquiry, register an account with us, or purchase or otherwise use a Bespoke product or service. We also collect personal information when you sign up or otherwise agree to receive informational updates, offers, and/or other notifications from us. If you apply to be a tutor with us, we will also collect all of the personal information that you provide on our application, including your employment experience, educational background and personal references.
3. Use of Personal Information: We may store and use your personal information for the internal purposes of ourselves and our affiliates, including, but not limited to, for purposes of administering our Sites, registering your account, otherwise enabling your use of our Services, and processing any inquiries, transactions, registrations or applications you submit. Examples of the foregoing include, but are not limited to, managing, processing and maintaining your purchases, transactions, and registrations, managing your account, communicating with you (including in response to any of your inquiries, registrations or applications), identifying your test scores or other results to your account, and sending you notices or reports about any of the foregoing or otherwise about our Sites or our Services. We also reserve the right to access, monitor and retrieve your personal information for compliance with our User Agreement. We may also use your personal information to inform you about other products and services we or our affiliates are offering, unless you notify us at any time that you do not wish to receive such offers. We also may provide aggregate information about our users and their usage patterns and preferences, without specifically identifying you, to advertisers, content licensors or others.
As a general policy, however, we will not disclose your personal information to any non-affiliated third party unless we have a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Bespoke; (ii) protect the safety, privacy, and security of users of our Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities. This general policy includes our not selling or otherwise licensing your email address to non-affiliated third parties. 2
If Bespoke sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, Bespoke may transfer your personal information to the party or parties involved in the transaction as part of that transaction.
4. Your IP Address and Anonymous Data; Cookies: We also collect data simply by the act of your visiting our Sites. Such data includes, but is not limited to, your IP (Internet Protocol) address and what we refer to as anonymous data, such as your browser type, operating system, platform, and referring web sites addresses. If you access our Services from a mobile or other device, we may collect certain information including the unique device identifier assigned to that device, operating system, browser type and other transactional information for that device. We use such data primarily to generate and study statistics regarding the demographics of users. We also use such data to generate and study statistics to help us understand how users interact with our Sites, in general, and specific pages of our Sites, in particular. To help us enhance and develop our Sites and our Services, we may also disclose such data to third parties (such as Google Analytics) in the form of aggregate demographics and usage statistics. Such third parties have their own privacy policies that govern their use of such aggregated data.
5. Links: Our Sites may at various times contain links to other web sites. Bespoke is not responsible for the privacy practices or the content of any linked sites. Please note that each linked site is governed by its own privacy practices and user or other similar agreements, and we make no representation regarding, and give no assurances regarding, the privacy or other practices thereof. If and when you visit any linked sites, you should read their privacy policies, user agreements, and any other posted statements that relate to your use thereof and their collection, use, and maintenance of personal information and anonymous usage data.
6. Security: Our Sites have been designed to include features that are intended to protect the loss, misuse, and alteration of your personal information. These security measures include SSL (Secure Sockets Layered) technology to ensure that all supplied sensitive/credit information is encrypted when transmitted and then stored in our firewall-secured, password-protected, databases. We limit access to our databases to those of our employees and authorized agents with a legitimate purpose for such access who are advised of this Policy and their confidentiality obligations. Any hard copies of such information are stored in a secure environment and access to such materials is also limited to those of our employees or authorized agents with a legitimate purpose for such access who are advised of this Policy and their confidentiality obligations.
7. Disclaimer: Notwithstanding the foregoing security measures, we cannot absolutely guarantee the privacy and security of your personal information provided by you or stored by us, including the security of our databases, and, notwithstanding this Policy, you should not have such an expectation. As outlined in more detail in our User Agreement, we specifically disclaim any liability to you or any other users for any non-compliance with, or breach or alleged breach, of this Policy, and your use of our Services means that you have agreed to assume this risk.
8. Children’s Guidelines: In order to comply with the Children’s Online Privacy Protection Act, as amended, and the regulations promulgated thereunder, students under the age of thirteen are not permitted to register with us directly. Bespoke requires the parents or legal guardians of such students to register, and complete any purchases, under their own names. The registration by the parent includes a consent to collect and maintain personally identifiable information for their child in connection with the provision of our Services, and is verified by provision of payment information that will be used for charges related to our Services.
9. Updates: We may change this Policy at any time, which changes will appear in this Policy and be indicated by a revised “last updated” line above. If the changes are material, we will also use reasonable efforts to highlight them via an online posting and/or an email to users. Changes will take effect immediately. If any change is not acceptable,
you may terminate your access to our Sites and our Services, but using our Sites or our Services after we have made or posted any such change means that you accept the change.
10. Contact: If you have any concerns about privacy or security at Bespoke, or wish to opt out of receiving notices about other products and services we or our affiliates are offering, we encourage you to contact us as specified in Contact Us at the bottom of our main website page.