PRIVACY POLICY

  1. 1. INTRODUCTION
    1. 1.1 Personal Information
    2. 1.2 Payment Information
    3. 1.3 Identity Verification
    4. 1.4 Non-Identifying Information/Usernames
    5. 1.5 Combination of Personal and Non-Identifying Information
    6. 1.6 Obligations
  2. 2. THE TYPES OF PERSONAL INFORMATION WE COLLECT AND HOLD
    1. 2.1 Cookies
    2. 2.2 Web Beacons
    3. 2.3 Embedded Scripts
  3. 3. INFORMATION RECEIVED FROM THIRD PARTIES
    1. 3.1Links to other sites
  4. 4. HOW WE USE PERSONAL INFORMATION
    1. 4.1 Do not track signals
  5. 5. INFORMATION SHARING AND DISCLOSURE
    1. 5.1 Information about Users
    2. 5.2 Service Providers
    3. 5.3 Receiving Information from Third Parties
    4. 5.4 Legal and Investigative Purposes
    5. 5.5 Internal and Business Transfers
    6. 5.6 Accessing, correcting, or downloading your personal information
    7. 5.7 California Privacy Rights
    8. 5.8 Exercising your other rights
  6. 6. DATA RETENTION
  7. 7. CHILDREN’S PRIVACY
  8. 8. POLICY UPDATES
This privacy policy was last updated on 23 December 2019.

1. INTRODUCTION

As part of our daily business operations, we collect personal information from our users and prospective users in order to provide them with our services, and ensure that we can meet their needs when providing these products and services, as well as when providing them with any respective information.

Your privacy is of utmost importance to us, and it is our policy to safeguard and respect the confidentiality of information and the privacy of individuals. ‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable. EduBirdie’s Privacy Policy applies to personal information collected and/or held by EduBirdie.

This Privacy Policy also explains how we process ‘personal data’ about people who use our services. We will review this policy regularly, and we may update it from time to time.

When you use the Service, you may provide us with information about you. This may include your name and contact information, financial information to make or receive payment for services obtained through the EduBirdie platform.

If you reside or are located in the European Economic Area (“EEA”) EduBirdie is the data controller of all Personal Information (as defined below) collected via the Site and of certain Personal Information collected from third parties, as set out in this Privacy Policy.

1.1 Personal Information

In the course of using the Service (whether as a User or Writer), we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). Examples of Personal Information include your name, email address, company address, and billing address.

1.2 Payment Information

If you use the Service to make or receive payments, we will also collect certain payment information, such as credit card, PayPal or other financial account information, and billing address.

1.3 Identity Verification

We may collect Personal Information, such as your date of birth to validate your identity or as may be required by law. We may request documents to verify this information, such as a copy of your government-issued identification or photo or a billing statement.

1.4 Non-Identifying Information/Usernames

We also may collect other information, such as zip codes, demographic data, information regarding your use of the Service, and general project-related data (“Non-Identifying Information”). Usernames are made public through the Service and are viewable by other EduBirdie Users.

1.5 Combination of Personal and Non-Identifying Information

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information, but EduBirdie will treat the combined information as Personal Information.

1.6 Obligations

You do not have a statutory obligation to provide us with any information, but you may have a contractual obligation to do so, and if we do not receive certain information from you, then we will not be able to provide our Service to you. If you have any questions regarding whether provision of information is mandatory and the consequences for withholding such information, please contact us using the contact information below.

2. THE TYPES OF PERSONAL INFORMATION WE COLLECT AND HOLD

We and our third party service providers, including analytics and third party content providers, may automatically collect certain information from you whenever you access or interact with the Service. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, and other information commonly shared when browsers communicate with websites. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you, to improve marketing, analytics, and site functionality.

The information we collect also includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Service. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Service, 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 Service.

2.1 Cookies

Like many websites, we and our marketing partners, affiliates, analytics, and service providers use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer or similar device (such as to save your registration ID and login password for future logins to the Service and to track your compliance with the EduBirdie Terms of Service) and session ID cookies, which expire at the end of your browser session (for example, to enable certain features of the Service, to better understand how EduBirdie Users interact with the Service and to monitor aggregate usage by EduBirdie Users and web traffic routing on the Service). You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functionality of the Service.

2.2 Web Beacons

We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Service is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Service, to monitor how EduBirdie Users navigate the Service, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.

2.3 Embedded Scripts

We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.

In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.

3. INFORMATION RECEIVED FROM THIRD PARTIES

We also may receive information about you from third parties. For example, we may supplement the information we collect with outside records or third parties may provide information in connection with a co-marketing agreement or at your request (such as if you choose to sign in with a third-party service). If we combine the information we receive from others with information we collect through the Service, we will treat the combined information as described in this Privacy Policy.

3.1 Links to other sites

On our website, you will encounter links to third party websites. These links may be from us, or they may appear as content generated by other users. These linked sites are not under our control and thus we are not responsible for their actions. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy.

4. HOW WE USE PERSONAL INFORMATION

The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes:

1. to provide the service or product you have requested;

2. to provide technical or other support to you;

3. to answer enquiries about our services, or to respond to a complaint;

4. to allow for debugging, testing and otherwise operate our platforms;

5. to conduct data analysis, research and otherwise build and improve our platforms;

6. to comply with legal and regulatory obligations;

7. if otherwise permitted or required by law; or

8. for other purposes with your consent, unless you withdraw your consent for these purposes.

The ‘lawful processing’ grounds on which we will use personal information about our users are (but are not limited to):

1. when a user has given consent;

2. when necessary for the performance of a contract to which the user is party;

3. processing is necessary for compliance with our legal obligations;

4. processing is necessary in order to protect the vital interests of our users or of another natural person.

5. processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our users.

4.1 Do not track signals

Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, EduBirdie does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser.

5. INFORMATION SHARING AND DISCLOSURE.

We may share aggregated Non-Identifying Information and we may otherwise disclose Non-Identifying Information to third parties. We do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing. We may also share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy, or in the following circumstances:

5.1 Information about Users

We share information regarding Writers who have entered into a Service Contract with a User. Note that if a Writer is suspended from EduBirdie, we may share that information with Users for whom that Writer has worked or submitted proposals for work. If you choose to submit a proposal for work as a Writer via the Service, we will share information relevant to your application with the applicable User(s), including, but not limited to, the information contained in your User Profile.

5.2 Service Providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of EduBirdie’s features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.

5.3 Receiving Information from Third Parties

You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of a third party application, that we share information about you with a third party and we will typically do so under those circumstances.

5.4 Legal and Investigative Purposes

EduBirdie will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of EduBirdie or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.

5.5 Internal and Business Transfers

EduBirdie may share information, including Personal Information, with any current or future subsidiaries or affiliates, primarily for business and operational purposes. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.

5.6 Accessing, correcting, or downloading your personal information

You have the right to request access to the personal information EduBirdie holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform, or wish to download all personal information we hold on you in a portable data format, please contact us. You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance please contact our customer support.

5.7 California privacy rights

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding 2018 sharing activities).

To obtain this information, please send an email message to [email protected] with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Under the California Consumer Privacy Act (“CCPA”), California residents have the right to know what personal information about them is collected, request deletion of their personal data, opt-out of the sale of their personal data, and not be discriminated against if they choose to exercise any of these rights. EduBirdie does not sell any of the data we collect about you. If you’d like to exercise any of the other rights afforded to you, contact us at [email protected].

5.8 Exercising your other rights

You have a number of other rights in relation to the personal data EduBirdie holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the services we provide. Much of the data we collect is in order to facilitate contracts between users, facilitate payments, and provide protection for the legitimate users of our marketplace – these data uses are protected against the below rights.

You have the right to:

– seek human review of automated decision-making or profiling

– opt-out of direct marketing, and profiling for marketing

– erasure

– temporary restriction of processing.

Erasure – Most personal information and user generated content cannot be deleted as they are used to support contracts between users, document financial transactions, and are used in providing protecting other legitimate users of the marketplace. In the case of non-personal data that can be linked with personal data, it will either be erased or otherwise anonymised from the personal data.

Temporary restriction to processing – under certain circumstances you may exercise this right, in particular if you believe that the personal data we have is not accurate, or you believe that we do not have legitimate grounds for processing your information. In either case you may exercise this right by contacting us.

6. DATA RETENTION

We will hold personal information, for as long as we have a business relationship with you, in secure computer storage facilities, and we take the necessary measures to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.

When we consider that personal information is no longer necessary for the purpose for which it was collected, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time. For example, we are subject to certain anti-money laundering laws which require us to retain the following, for a period of 5 years after our business relationship with you has ended.

Also, the personal information we hold in the form of a recorded information, by telephone, electronically or otherwise, will be held in line with local regulatory requirements. If you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications. We may keep your data for longer than 5 years if we cannot delete if for legal, regulatory or technical reasons.

7. CHILDREN’S PRIVACY

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

8. POLICY UPDATES

We may occasionally update this policy. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy. We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.