Privacy Policy
Established: August 2020
At 2686069 Ontario Inc. d.b.a. LumenEd (“LumenEd”), your right to privacy is very important to us. We provide an online platform known as lumened.io that connects tutors with individuals seeking tutoring services, and other services related thereto, through our website and virtual classrooms, allowing users to interact via the LumenEd platform’s interface or other methods as may be made available by LumenEd or our partners from time to time. In order to provide you with this service effectively, we collect certain specific information from you, and we also automatically collect information and data relating to the usage of our services by all our users, including you. Because we are committed to protecting your privacy rights and the information you provide to us, we have developed this privacy policy. It explains how we will protect your information and describes how we will use and share it.
This policy is concerned with the protection of your personal information only. Personal information includes any data that can be used to identify you as an individual, including your name, income, personal opinion, interests, home contact information, identification numbers, user IDs, passwords, ethnic origin, and age. Under Canadian law, in a business context, personal information does not include the name, job title, business address, or business telephone number of any employee in an organization.
This policy describes the following practices:
- Collecting information
- Sharing your personal information
- Maintaining your personal information
This privacy policy may change from time to time to reflect LumenEd’s internal needs, customer feedback, or changes in applicable privacy legislation. LumenEd will post all such changes on our website, so please visit this page regularly.
Collecting information
In order to use the services provided by LumenEd, you will be required to provide specific information about yourself, such as your name, address, telephone number and e-mail address. We will always inform you when we need information that personally identifies you, and we will keep this information in strict confidence. Additionally, you may, on occasion, voluntarily provide LumenEd with information that can be classified as personal information – all such personal information will be stored and maintained in accordance with this privacy policy.
We collect information about you in the following ways:
As part of your use of LumenEd’s services
Whether you are a student or tutor, LumenEd will require a certain amount of personal information to enable others to contact you to facilitate tutoring services. If you apply as a tutor, the profile you create on our website will be publicly accessible unless otherwise indicated. You may change the privacy settings of your profile and edit the content at your own discretion.
Parents or guardians of students who are minors are responsible for registering for LumenEd and tutoring services on such child’s behalf, as set forth in LumenEd’s Terms of Service, and shall be in control of, and responsible for, any disclosure of personal information relating to the child in relation to the child’s use of the tutoring services as a student. LumenEd expects parents or guardians to be the primary contact with respect to any use of services obtained through LumenEd; there is no need for personal information of any minor to be disclosed except with the parent’s or guardian’s consent. Further details are set forth in the section below, “Information relating to minors”.
We will also require your name, address, telephone number and certain financial account or credit card information, for billing and payment purposes. This information is kept confidential and stored securely by LumenEd and its payment provider. For greater certainty, LumenEd will not provide student payment information to any tutor.
LumenEd also reserves the right to monitor messages sent by you, or data posted by you, through the services, in order to ensure that your use of the services is appropriate, lawful, and in accordance with LumenEd’s terms of service.
Automatically by LumenEd’s software and services
LumenEd’s software and services contain features that automatically collect information from users, such as usage statistics and other tracking information. Although this information will not identify you personally, it nevertheless provides certain information about you, and we therefore treat it as personal information. Additionally, use of LumenEd’s website and/or software may result in the collection of technical information such as your computer’s IP address, operating system, browser name/version, the referring web page, requested page, date/time, and sometimes a “cookie” (which can be disabled using your browser preferences); such information is used to help us understand the overall usage pattern of our website and software.
You contact LumenEd directly
Customers and business partners often contact us directly. When you contact any LumenEd employee by telephone, e-mail, in person, or through our website, you will be asked to provide consent to the collection of personal information if your personal information will help us deliver the information, products, or services you require.
You respond to communications from LumenEd
From time to time, LumenEd may invite you to provide us with information for specific purposes. We may ask for this information through feedback features on our website or software; we may send out e-mail inviting feedback or offering products and services; or we may ask you for information concerning support of our products or services. Your response to these communications may require you to submit personal information and opinions at your discretion.
Your information is obtained through a third party
Occasionally, LumenEd will obtain information about you from third parties, such as mailing list providers, third party service providers, ISPs, or third party application or account providers. Third-party providers are responsible for obtaining consent for the release of personal information to us from those individuals identified on mailing lists, surveys, or through other collection methods.
Third party collection of your information
Due to the nature of the services provided by LumenEd, third parties may collect information from you through the use of websites that are accessed by you through the services. Additionally, these websites may ask you to provide additional information directly to third parties. Third party products or services provided through these websites are not owned or controlled by LumenEd, and are governed by the third party’s terms and conditions and/or privacy policy. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.
Information relating to minors
LumenEd products are specifically designed to function without third party access to a child’s personal information. We do not collect or retain any personal information from children except as needed to facilitate tutoring for that student, who may be a minor. LumenEd is committed to complying fully with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). Other than tutoring services and free information and materials that do not require any registrations or identifying information, LumenEd content on it’s website is not directed at children under 13 years of age, and LumenEd does not knowingly collect personally identifiable information directly from children under 13 years of age online. For purposes of using the LumenEd’s website as a platform to connect with tutors, parents or guardians may supply information such as name or age of their children in order for LumenEd to assist in facilitating the connection between student and tutor. LumenEd may store this information, and if so stored, it will be done so in a secure digital format. Parents or guardians of children under 13 years of age may review or have deleted any personal information previously provided by the child, parent, or guardian that is ultimately collected by LumenEd, if any, to connect the child with a tutor. If you seek to review or delete such information, contact LumenEd at the below email address indicating what you would like to have done and LumenEd will contact you for purposes of taking the requested action.
Sharing your personal information
Subject to any exceptions stated above in the collection of information section, should LumenEd collect any of your personal information, we will follow these practices regarding the distribution of that information.
Your personal information is protected
LumenEd uses reasonable precautions to protect your personal information and store it securely. Access to your personal information is restricted to those persons who need it (including students and tutors, as applicable), and LumenEd takes reasonable steps to prevent the unauthorized use or disclosure of your personal information.
LumenEd only uses and discloses your personal information if it helps us facilitate your needs, improve our products and services, meet legal and regulatory requirements, or — to the limited extent possible — manage our internal business operations. Additionally, if there are any disclosure or use restrictions in your consent to the collection of your personal information, LumenEd will abide by those restrictions (subject to the consent exceptions listed below). For example, your credit card or financial information will only be used to bill you for the services that you have authorized or used, or to pay you for the services performed, as applicable.
LumenEd may combine your information with other information into an aggregate form, so your information no longer personally identifies you. We may then disclose the aggregate information to third parties, so they can obtain an overall picture of LumenEd’s products, services, customer sectors and/or usage patterns.
We only share your information with your consent
LumenEd provides your information to third parties only for purposes to which you have consented, and we require such third parties to keep your information confidential.
In a few situations, LumenEd may be required to disclose your information without your prior consent. For example, LumenEd may disclose your information if we are required to do so by law, or if we believe in good faith that such disclosure is necessary to:
- comply with law or legal process
- protect and defend our rights and property, or the rights and property of a third party
- protect against misuse or unauthorized use of any of LumenEd’s products, services, or other proprietary materials
- protect the personal safety of any person
- allow for a change of ownership of LumenEd and associated transfer of all personal information to the new owner of LumenEd – this does not affect the protection of your information under this Privacy Policy
LumenEd will always try to provide you with prior notice of such disclosure; however, such notice may not always be possible or reasonable given the circumstances.
Additionally, the nature of the services provided requires the routine use of your information in the provision of the services. Your personal information will only be used to the limited extent necessary to provide the services that you have requested, and may include the following uses:
- to allow third party suppliers, vendors, contractors and other parties to provide products and services to us or to you, or to otherwise act on our behalf (this may include, without limitation, our authorization of such third parties to email our users regarding updates, surveys and other inquiries regarding their experience with our service); and
- to allow for audits and surveys to, among other things, validate the size and composition of the users of LumenEd’s services, and understand their experience with LumenEd’s service.
Maintaining your personal information
LumenEd has established the following practices regarding the maintenance of your personal information.
You can request access to your personal information at any time
If, for any reason, you wish to review your personal information that LumenEd has in its possession, you can contact our Privacy Officer, who will be pleased to provide you with all your personal information that LumenEd has on file.
You can request changes to your personal information at any time
Sometimes, it will be necessary for you to update your personal information LumenEd has on file. For example, if you change payment account information, you must update your information in order to keep receiving the services provided by LumenEd. In many cases, you will be able to do so by changing your personal settings on your account.
If you wish to make any changes or corrections to your personal information that cannot be done yourself through your personal settings, please contact our Privacy Officer who will implement the changes. This will help us ensure our records are always up-to-date.
You can opt out of communications at any time
Additionally, you always have the choice of whether you wish to receive information – such as e-mail updates – from LumenEd. In some cases, you may do so simply by changing the preferences on LumenEd’s website or virtual classroom.
If you do choose to opt out of communications respecting services provided by LumenEd, you may not obtain all the benefits we could otherwise provide, such as updates or warnings. LumenEd will not have any liability to you for your loss of those benefits or any negative effects respecting your use of LumenEd’s services.
You can request that your personal information be destroyed at any time
A situation may arise where you desire to have all of your personal information that is contained in LumenEd’s records deleted or destroyed. If this is what you wish, please contact our Privacy Officer, who will take care of removing your personal information from all of LumenEd’s records. However, there may be situations where we are obligated to retain one archival copy of your information to allow us to comply with laws or respond to legal processes. We will inform you of all such situations, and will only use your retained personal information to the limited extent necessary to comply with such laws or respond to legal processes.
We follow general principles consistent with applicable privacy laws
We comply with all applicable privacy laws respecting our processing and storage of any personal information that may be used in conjunction with the Services, and we deal with your data under these general principles:
- Lawfulness, fairness and transparency: We may not reveal the granular details of how we protect your data, because that would compromise its security – but we will let you know why we need it, what we need it for, and process it securely and in accordance with applicable laws. If you have any questions respecting your data and how it’s being used, you need only ask us, and we will make every effort to provide a thorough answer.
- Limitations of purpose: We will limit use of your data to the extent necessary to provide you with our products and services, with the clear exceptions that are set out in this Privacy Policy
- Minimization of data: We only collect information that we need, and that you choose to give to us. We will not collect personal information gratuitously from you for no reason.
- Accuracy: We make reasonable efforts to keep your data accurate and up to date, based on your input; if you notify us of any changes to your data, we will make sure to change it in our systems in a timely manner.
- Limitation of data retention: We believe in streamlining the way that we handle data so that it minimizes data redundancy and unnecessary retention.
- Integrity and confidentiality: We process your information using appropriate technical or organizational measures designed to ensure appropriate security of your personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.
Other Matters
Refer-A-Friend
If you choose to use our referral service to refer a friend to our website or services, we will ask you for your friend’s name and email address. We will automatically send your friend an email inviting him or her to visit the website. LumenEd stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. You are solely responsible for obtaining your friend’s consent to the disclosure of such information to LumenEd prior to using the referral service, and will indemnify LumenEd against any liability to such friend relating to the use of such information in the manner described above. Such information will otherwise be handled by LumenEd in accordance with this Privacy Policy. The foregoing shall also apply to any other referral or invitation of third parties that you desire LumenEd to make on your behalf with respect to LumenEd’s website or services.
LSOs
Third Parties, with whom we may partner to provide certain features on our website or to display advertising based upon your Web browsing activity, use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
Behavioral Targeting
We may partner with a third party ad network to either display advertising on our website or to manage our advertising on other sites. Our ad network partners may use cookies and Web beacons to collect non-personally identifiable information about your activities on this and other websites to provide you targeted advertising based upon your interests. Various browsers and third parties may offer their tools for blocking or removing such advertising.
Social Media Widgets
Our website may include Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our website. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.
Customer Testimonials
We post customer testimonials/comments/reviews on our website which may contain personally identifiable information. We do obtain the customer’s consent via email or other means prior to posting the testimonial authorizing us to post their name along with their testimonial. To request removal of your personal information from testimonials/comments/reviews please contact us at info [at] LumenEd.io.
Blog
Anytime you post on our blog please be aware that you are posting using a third party application, and we may have no access or control over this information. To request removal of your personal information from our blog, you can either log into the third party application and remove your comment or you can contact the appropriate third party application. Your interaction with these features is governed by the privacy policy of the company providing it.
Contacting us
LumenEd welcomes your comments about this privacy policy, and we would be happy to provide any additional information you require. Please contact our us at:
Info [at] LumenEd.io
This privacy policy supplements any agreements you already have with LumenEd, such as your Terms of Service, website and virtual classroom terms and conditions of use, and any other agreement. Our privacy policy does not replace the terms of those agreements. By agreeing to those terms and using LumenEd’s website, products, software and services, you are consenting to the collection and use of your personal information by LumenEd in accordance with this privacy policy. This policy was written in accordance with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA).