Class.Me
PRIVACY NOTICE
Recently Updated: December 2019
This Privacy Notice (“Privacy Notice”), is an integral part of Class.Me Terms of Use, which can be found at: http://class.me/terms.html, and governs the use, processing and transfer of data collected via Class.Me mobile applications, including the Class.Me for school app (“Class.Me App” or “App”), and through the Class.Me website available at: http://www.class.me/ (collectively, “Services”), with respect to each person (“User”, “you”) accessing or using the Services operated by Class.Me Ltd. and its subsidiaries (“Class.Me”, “we” or “our”). Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms.
If you choose to use the Services, register and interact with the Class.Me App or otherwise provide data to us, you explicitly agree to the use of such data in accordance with this Privacy Notice, and represent and warrant that you will comply with the provisions herein. You may not use the App or the Services or submit any data through them if you do not agree to any of the terms hereunder. This Privacy Notice shall not be construed in any manner to derogate from the Terms or any other agreement or understanding between Class.Me and you.
Please note that, the Class.Me App and/or Services may contain links to other websites, products or services offered by third parties, which are not governed by this Privacy Notice. This Privacy Notice does not apply to the practices of entities which are not controlled by Class.Me.
THE HIGHLIGHTS:
· The Class.Me App is based on a unique technology developed in order to enable communication between schools that subscribed to the Services, their students and the School staff (i.e., teachers). The App allows students and teachers to communicate, set-up tasks, creating a safe space for students to ask questions and receive answers, creating user groups to distribute information, creating Q&A forums, connecting to exam databases, etc.
· The App also allows schools to access a designated dashboard that includes information and insights regarding each student that uses the Class.Me App. This information may be statistic or identifiable. Please note, this information is based on the information collected via the App or otherwise uploaded to the App by either the student or the school (including the teachers). This information is not public and is available solely to the School’s authorized personnel.
· The App may also suggest students with educational solutions, such as connecting between Class.Me’s private tutors and students etc., all as explained in broadly in our Terms and this Privacy Notice.
· Children under the age of 13 (and in certain jurisdictions under the age of 16) are not permitted to use the Class.Me App without parental or legal guardian consent. For more information about how we process children’s’ Personal Data please read this privacy policy thoroughly.
· You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.
· You may not share Personal Data about other people with us who you are not authorized to share or use.
· You may be entitled under applicable law to request to review, amend, erase restrict and opt-out from the processing of your Personal Data.
· We share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances as specified herein.
· If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: privacy@class.me
1. What are Personal Data, and what data is collected by Class.Me?
“personal data” or “personal information” (will be referred together as “Personal Data”), means, subject to applicable laws, information which identifies a natural person, including, but not limited to, first and last name, phone number, email address, online identifiers, ID number, billing information, information concerning households, devices, etc.
Personal Data regarding Users of Class.Me App For Schools:
There are a few types of Users in our Class.Me App, they may consist of: (i) schools that subscribed to our App and their representatives (e.g., school personnel your teachers) (“School”); (ii) students who registered the App with School’s unique code (each a “Student”); and (iii) parents of Students who received the School’s code to use the App, and were also invited to join their kids’ group. We collect certain Personal Data regarding these Users when they register the App and interact with it, for example, this include Personal Data technical/behavioral data, such as operating system and language preferences, contact information such as: name, phone, number, access authentication to the App or Services, content you upload to the App (e.g., messages, audio recordings and photos) customer support communications and data regarding the use of our Class.Me App. In the event you are using the App or the Services on behalf of the School you work for(e.g. the School designated dashboard) we may collect and process additional information about you, such as the name of the school (i.e., your employer), the credentials you use to connect the App and the dashboard, etc.
For more information please refer to Section 3 “How and Why Class.Me Processes Data”
Notice to Parents:
· If you are a parent or a legal guardian of a User, please not that we may collect information about you in order to ask you to provide Parental Consent (as defined below) and/or if you use the App.
· In order to use the Class.Me App we will collect and process Personal Data regarding your child.
· When parental or legal guardian consent is required (“Parental Consent”), we may collect and process information coercing Students’ parents or legal guardians. Such information includes your name, phone number, your kid’s name, etc. Additionally, we may process your information in case you are using the Class.Me App as explained above.
· To learn more on the information we collect and process with respect to your child, please continue reading this Privacy Notice.
· Please note, that if we don’t receive your consent, within a reasonable time, your child could not use the App and we will delete your personal information.
Non-Personal Data
We collect non-personal data regarding Users concerning their use of the Class.Me App and the Services, such as the scope, frequency, latency, and aggregative and statistic information regarding User’s use of the App and Services.
Special Categories of Personal Data
We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person’s sex life or sexual orientation.
In the event you become aware that such data has been posted to the App or collected by us unintentionally, please inform us immediately.
Users may choose to upload to the App a profile picture or audio recording. This is entirely voluntary. If the User uploads a profile picture, such actions shall be deemed as the clear indication of the user's consent to the transfer of such data to us. Such data will be processed in accordance with this Policy.
General Class.Me App
Please note, that in the event you are using the general audience Class.Me App (i.e., not the Class.Me App for Schools) solely the provision applicable to you shall apply. For example, you can use the App without having the School’s code. Please note however, that not all features may be applicable to the general audience Class.Me App.
2. How and why Class.Me processes data
Non-Personal Data
Non-Personal Data is used mainly for click stream analysis in order to maintain and develop our App and Services, including among others, in order to measure and understand the level of engagement with the Services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of the Class.Me App and/or Services and for developing new services and features.
Personal Data
Personal Data is only used for limited purposes, as specified below.
Type of Data |
Purposes of Processing |
For EU persons - Legal Basis under the GDPR |
|
Personal Data regarding App Users: Name, age, phone number, access authentication to the App (via Firebase), information uploaded by the Users, such as text messages (e.g. posts and comments and photos that a User uploads), profile picture you choose to upload to your profile, and audio recordings you upload to the App etc. This information is collected directly from you through the App. |
To provide the Services to the User; To sign-up registration and to identify authorized Users to access the App and perform activities. To resolve any disputes, communicate with you regarding customer service and support issues, and to respond to questions or comments and help resolve any problems. |
- In case you are a Student under the age of 13 (or where applicable under the age of 16) we process your data based on parents or legal guardian active consent. - Necessity of processing for the purposes of the legitimate interests of the User and Class.Me. - To perform the contract which the User is a party or in order to take steps at the request of the User prior to entering into a contract. |
|
· Technical Information, Geolocation and Online Identifiers: We collect technical information transmitted by your device, including but not limited to: type of browser, operating system, type of the device used to access Class.Me App and Services, date and time stamp and language, preference approximate geolocation (i.e., country), Wi-Fi usage, User’s actions such as page views, search queries, etc. In addition, when you access the App or use the Services, we collect your IP address (“Online Identifiers”). Note that, while the Online Identifiers are considered personally identifiable information in many jurisdictions (such as the EEA and in California), there are some jurisdictions in which such data sets are not considered as Personal Data. We treat the Online Identifiers as Personal Data, in accordance with applicable laws. This information is collected automatically via the App. |
We collect this type of information for the purpose of operating, providing, maintaining, protecting, managing, customizing and improving our website, Class.Me App and Services and the way in which we offer them; enhancing your experience with the Services; auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the Services. |
- In case you are a Student under the age of 13 (or where applicable under the age of 16) we process your data based on parents or legal guardian active consent, as provided upon registration to the Services. - Necessity of processing for the purposes of the legitimate interests of the User and Class.Me. - To perform the contract which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract. |
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Contact Us Information We collect Personal Data you actively contact. This information usually includes your contact details and a text message you submit to us. |
To answer your queries and provide you with the services you requested from us. |
- Necessity of processing for the purposes of the legitimate interests of the User and Class.Me. - To perform the contract which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract. |
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Class.Me App or the Services and to enforce the Terms, as well as to protect the security or integrity of our databases, Class.Me App and the Services, and to take precautions against legal liability. Such processing is based on out legitimate interests.
3. Will Class.Me Share Personal Data With Others?
Non-Personal Data
Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users.
Personal Data
We may share Personal Data only under the following limited circumstances:
§ With trusted partners and third parties who assist us in operating the Services and conducting our business, such as fraud prevention, cloud storage services, private tutors, account maintenance and technology services.
§ With the Schools that sign-up for our Services. We provide them with a designated dashboard of insights regarding the School students, based on the information provided by the Users through the App.
§ With third parties if necessary to comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
§ Other third parties with your consent to do so.
§ In the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In such case, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Notice.
4. Will Class.Me transfer Personal Data internationally?
Our databases are currently located in the US. Some of our processing activities are made in the EU and the State of Israel as well. With respect to processing activities in the State of Israel, the European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.
Any other transfer of Personal Data originating from the EU to a third country (other than to the State of Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users' rights.
5. Will I receive promotional materials from Class.Me?
We currently do not send Users any commercial or promotion information via direct mailing such as emails messaging. We will not send any User such promotional mailing without obtaining the User's explicit prior consent.
6. Data Subjects' Rights
For information regarding your rights in connection with your Personal Data, see our Users Rights Policy http://www.class.me/DSR.html http://www.class.me/user-rights.html
The Class.Me App is directed to, inter alia, Students of the School that engaged with us for the use of the Class.Me App. This means that Students under 13 years old, or under 16 years old in certain jurisdictions (“Child” or “Children”), will not be able to use the App without their parent or guardian consent.
If we become aware that a Child has provided us with Personal Data without appropriate consent, we will delete such data from our databases and cease to provide him/her the Services, and as this constitutes an infringement of our Terms Class.Me we may terminate and delete Child’s account.
Note for parents and legal guardians: you may provide your permission and consent for the use of the Class.Me App by your Children, and allow Class.Me to collect, use and disclose the information of your Child as set forth in this Privacy Notice, by providing a written approval through either: (i) this form; (ii) provide the school with a written applicable consent form (as may be provided by the School); or (iii) if applicable, through an online feature available on the App, that may involve sending you an email or SMS .
Changes and Updates
We may update this Privacy Notice from time to time. We encourage you to periodically review this Privacy Notice to stay informed about our practices related to the collection and processing of Personal Data.
7. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT
This section for California Residents under the California Consumer Privacy Act of 2018 (“CCPA”) supplements the information contained in our general Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “you”), as defined under the CCPA. Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. Further, this Privacy Notice is an integral part of our Privacy Notice and thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Notice.
As required under the CCPA, we will update this Privacy Notice every 12 months. The last revision date will be reflected in the “Recently Updated” heading located at the top of the Privacy Notice.
types of PERSONAL information we COLLECT
Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The categories of Personal Information that we collect (and has collected within the last 12 months), are detailed in the table below.
Please note that, under the CCPA Personal Information does not include: publicly available information from government records and de-identified or aggregated consumer information, information excluded from the CCPA’s scope (e.g., health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA)); and information covered by certain sector-specific privacy laws (e.g., the California Financial Information Privacy Act (FIPA)).
Category |
Examples |
Collected |
A. Identifiers. |
A real name, , unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers. |
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B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
Yes |
C. Protected classification characteristics under California or federal law. |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
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D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
No |
E. Biometric information. |
Photos and audio recordings |
Yes |
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. |
Yes |
G. Geolocation data. |
Physical location or movements. |
No |
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
Yes |
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
No |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
Yes |
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows: (i) directly from you, for example, when you register and provide information through the Class.Me App; (ii) automatically when you use the Class.Me App.
USE OF PERSONAL INFORMATION
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
· To fulfill or meet the reason you provided the information. For example, to provide you with the App services and features, or if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry.
· To provide, support, personalize, and develop our Class.Me App and Services, as well as improve our Services.
· For security and fraud detection purposes, and to maintain the safety, security, and integrity of our Services.
· For testing, research, analysis, and product development, including to develop and improve our Class.Me App and Services.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING AND SELLING DATA
We may disclose and sell (“selling” under CCPA relates to any disclosure, transfer, and selling of Personal Information for monetary or other valuable consideration) your Personal Information to a third party for a business purpose. When we sell or disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
We share or sell your Personal Information to the following categories of third parties:
(i) We share your Personal Information with our service providers (such as: Google Cloud and Firebase)
(ii) We share your Personal Information data aggregators (such as: Coola data and Google Analytics)
(iii) We may sell your Personal Information to our business partners (such as: private tutors that will provide you with certain services, in case you will choose to engage with them and, where applicable subject to your parents’ consent).
Children
· Parental Consent. If you are a child under 13 years of age, we will not sell your Personal Information without first obtaining parental or legal guardian consent.
· In the event that you are at least 13 years of age but less than 16 years of age, we will ask your consent before selling your data.
You may exercise your right to opt-out from the selling of your Personal Information by clicking “Do Not Sell My Data” button available on our website. [Company: you need to embed such button on the website].
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE OR FOR SELLING PURPOSES
In the preceding twelve (12) months, Class.Me has disclosed or sold the following categories of Personal Information for a business purpose:
Category A: Identifiers.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Category F: Inferences drawn from other personal information
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
The CCPA provides consumers with specific rights regarding their Personal Information. Please review our Privacy Rights Policy regarding your rights under applicable law.
You may exercise any or all of your above rights in relation to your Personal Information by filling out the Data Subject Request (“DSR”) form available here http://www.class.me/DSR.html and send it to our privacy team at: privacy@class.me.
CONTACT US
If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at:
Class.Me Ltd.
privacy@class.me
6th Shienman Pinchas St. Tel-Aviv, 6912716, Israel.