Privacy
Last updated on: April 1st, 2024
This Privacy Policy (“Notice”, “Policy”) governs the manner in which Coral Academy (“we”, “us”, or “our”), an online education-oriented marketplace platform, may collect, use, maintain, disclose or process the personal information of the users of our Services, including teachers, students, and minor students' parents or legal guardians, (“user”, “you”, “your”, or “yours”).
By visiting, accessing, or utilizing our Services, Content, and Website (which may undergo modifications, relocation, and/or redirection from time to time as and when required), or by contacting us through our Services or via email or any other designated methods provided on the Website, you explicitly acknowledge that you have comprehensively read and understood the provisions outlined in this Privacy Policy. Additionally, you provide your consent for us to collect, utilize, maintain, disclose, and/or process your personal information for all purposes described hereunder. If you do not consent to the collection, use, and/or disclosure of your personal information for the aforementioned purposes, including the personal information of your minor ward or child as specified in this Notice, you may exercise the option to refuse the collection of specific information, wheresoever applicable, by sending a mail to us or by choosing to discontinue or cease your use of our Services and Activities.
Kindly note that this Policy applies to personal information in our possession or under our control, including personal information in the possession of organizations that we have engaged to collect, use, disclose, or process personal information for our purposes, but not data that do not fall under the purview of personal information, including, but not limited to, aggregated or statistical data which we may use for analytical and other purposes. It also does not apply to the personal information of our employees, directors, owners, advisors.
This Notice lays out:
1. Key Definitions of Terms used Hereafter
2. The Categories of Personal Information Collected and Used by Coral Academy
3. Where your Personal Information may be Collected from and Used by us
4. The Purposes for which your Personal Information may be Disclosed
5. Children’s Privacy
6. State-specific Information
7. How your Personal Information is Protected
1. Key Definitions of Terms used Hereafter
The following Key Terms are used repeatedly in the information provided throughout our Policy and are for all intents and purposes defined as specified hereunder.
Customers include Students and their Parents, Teachers, and Partners.
Students are defined as minors, aged 18 years or younger, who participate in Coral Academy’s classes and activities in any way, shape, or form;
Parents are defined as the parents or legal guardians of the aforementioned students;
Teachers on our platform are independent contractors - either individuals or organizations - who offer classes through our platform;
Partners are companies or third parties that we may work with, such as schools, technology vendors, employers, customer services, or non-profit organizations, and who are not “teachers” as defined above;
Classes here refer to the courses developed/taught by Teachers on our platform;
Activities are defined as the groups, reviews, forums, and other types of engagement through or with Coral Academy in which any Customers may participate, whether paid or free;
Personal Information/Data means information linked to an identified, or otherwise potentially identifiable, person;
Services refer to the Classes or Activities stated above, or any other such engagement by Customers with the Coral Academy platform; and
Process refers to any activity relating to your personal information/data, as regards collecting, using, maintaining, storing, sharing, or processing said data.
These Terms may find mention in the following sections of our Privacy Policy and can be referred to as and when required, in order to understand how they are defined by us.
2. The Categories of Personal Information Collected and Used by Coral Academy
The pertinent sets of personal information mentioned hereunder are governed by the nature of your interaction(s) with the Coral Academy Platform and Website, and they may therefore vary from person to person, depending on how they choose to engage with our platform. These categories of personal information, which include, but are not limited to, information provided to us by your engagement with Coral Academy, as well as passively collected information, are specified below.
i. Identifying Information and Contact Details, such as your real legal name, telephone number, e-mail address, date of birth, and photographs. We may also process general information about the nature of your inquiry and/or interactions with Coral Academy, along with your username, password, mailing address, and other information related to providing you services through our Website, should you choose to register for the same.
ii. Financial and Payment Details, such as the payment and bank account information our teachers provide to receive payment for their services on our platform. For security reasons and keeping your privacy in mind, Coral Academy in no way stores sensitive information as legally applicable.
iv. User Content, including Sensory and Surveillance Data such as voicemails, recordings, transcripts, and any other audio-visual data in connection with the recorded Services available on our platform. This may be collected when you are registering for the classes, avail our Services, contact customer or technical support, and contact us otherwise. Additionally, any feedback, photographs, or recordings from your end, not excluding audio or video recordings you submit as regards customer support, may or may not fall under the ambit of User Content collected, recorded and/or stored by us. Said recordings and transcripts, however, are solely maintained for the purpose of internal quality checks and will not be made available to anyone except for the Coral Academy Team and its affiliates.
v. Communications Data, comprising the content of such communications as well as metadata about the same (such as the date, time, and contact source), along with Likeness Data which includes but is not limited to comments, surveys, online forms, chats, any feedback collected from parents/students/teachers and any other such activities you participate in. This information serves to help Coral Academy in continuously striving to better our platform and address common issues our Customers may face.
vi. Third-party Information, including both that is obtained from third parties about you and that is provided about third parties by you. The latter may consist of personally identifiable information about others that you may provide us, such as in the eventuality that you choose to use our referral service to refer someone you know. It must be made clear that if you provide us with personal information concerning another individual, it is solely your responsibility to ensure that you have the necessary authority and/or permission to do so and to authorize us to use their personal information in accordance with the terms outlined in this Privacy Policy.
vii. Demographic and Interests-based Data about you to tailor our recommendations, such as your gender, age, state, city & country of residence, and your interests in teaching or learning additional classes, as may be the case, which is inferred based on subject matter(s) you may have previously engaged with.
viii. Combined Data obtained from various sources other than yourself, such as through partners, employers, third parties, or social media. Potential third parties in this case include any accounts you may have through your school or employer, and also directly. We may try to combine these different sources of information, wheresoever feasible, to create a comprehensive overview of individuals who are engaged with us for our reference.
ix. Information about User Activity and Analytics, respectively, the browser type, search terms, items you may click on our Website, error messages displayed to you, pages you viewed including the referring site, subsequent site, and date/time of each visitor request obtained from internet and network activity; and cookie information vis-a-vis third party analytical tools like Google Analytics & other apps/parties/platforms to assist us in analyzing and improving our Website on a regular basis.
3. Where your Personal Information may be Collected from and Used by us
The kinds of sources wherefrom personal information may be collected are:
i. You: Our platform gathers personal information from individuals, or from their parents or legal guardians in case they are under the age of 13, when provided voluntarily through our Services.
ii. Teachers/Students: In the case of teachers, we may receive personal information about students, such as progress evaluations, which is shared with us by the teachers. Similarly, with regard to students, we may receive personal information about teachers, such as teacher feedback, which is provided by the students.
iii. Automated and Recording Technologies: As previously mentioned, we also collect Internet Activity information through automated technologies implemented on our Website as well as recording technologies with due consent to the extent mandated by law.
iv. Background check providers: To comply with relevant regulations, we may acquire background check reports concerning teachers from relevant third-party providers.
Accordingly, the personal information so obtained may be disclosed to, and used by, the following third parties:
i. Teachers: When Parents register for our Services, they acknowledge and consent to the fact that Teachers may receive specific personal data about themselves and their children. This data includes information about the classes the Students have taken, their requests and interests, as well as the username of the Student. This sharing of information occurs prior to the commencement of the course.
Teachers may receive additional personal information about Students directly from the Students themselves, but only to the extent that the students provide it voluntarily. Keep in mind that the independent Teachers on our platform are not considered our employees or agents, and they do not process personal data on our behalf. Although we act solely as limited agents, we do still have certain requirements established for Teachers to agree to follow regarding their handling of personal data.
Moreover, we collect such information only to the extent that it is necessary or appropriate to fulfill the purpose of the User's interaction with Coral Academy.
ii. Students: Teachers must note that we may disclose certain personal information, in order to assist students (and the parents or legal guardians of minor students) in the course and teacher selection process as necessary. On the other hand, it is important for Students to be aware that their interactions with other Students through group participation in Classes and Activities on our platform, may be visible, audible, and accessible to all participants for viewing or reading purposes. This may include other Parents, Students, and any other individuals if necessary for participation, such as interpreters.
In such cases, we recommend that parents carefully review the websites or tools listed by teachers for specific classes. It is essential for parents to examine these sites and tools and either give their consent or notify us or the teacher if they disagree with their usage. Parents and Students should also thoroughly check email registrations and carefully review the description or listing of Classes before opting for them.
iv. Our Service Providers and Third-party Vendors: We disclose your personal information to third-party service providers, agents, and other organizations to facilitate the provision of our Services and fulfill our obligations in relation to the provision of those Services. These may include, without limitation, providers of email services, hosting services, cloud storage, maintenance services, backup services, analysis services, communication software, marketing services, business strategy services, banking services, payment processing services, professional services, background check services, and more.
Furthermore, we may share non-personal information, such as aggregated user statistics, de-identified information, demographic information, and similar data, with third parties including advertisers, content providers, and analytics providers. This is done to support various objectives of Coral Academy, such as improving our services, delivering targeted advertisements, and conducting research and analysis.
v. Affiliated Companies: We may share your personal information with our subsidiaries, related corporations, affiliates, licensees, and business partners for the sole purpose of providing the Services and fulfilling obligations associated with the provision of the Services or any requested products and/or services. Such sharing of information is limited to the specific purposes for which the information was initially collected, and these companies are not authorized to utilize your personally identifiable information for any other purposes.
In addition, we may disclose required information to third parties with whom we have a commercial relationship, such as those governed by an affiliate marketing agreement.
vi. Corporate Transactions: In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, insolvency, sale of company assets, or transfer of service to another provider, your information may be transferred to a successor or affiliate, either alone or as part of the overall transaction, along with other assets. This transfer may take place during the transition or evaluation phase, even before the transaction is completed. However, whenever possible, we will ensure that the receiving entity upholds the privacy protections associated with your information.
vii. Requested Disclosures: Under certain circumstances, we may be obligated to disclose personal information in legal proceedings, including court proceedings, in response to a court order, subpoena, civil discovery request, or any other legal process. This requirement may also arise from the applicable laws or regulations, including codes, listing rules, or guidelines in relevant jurisdictions.
In such cases, we may disclose personally identifiable information to safeguard the rights, property, or safety of Coral Academy, or of our user(s) or any other individual. Correspondingly, we also reserve the right to disclose personally identifiable information to investigate or prevent a violation of the user's contractual or other relationship with us or the commission of any illegal or harmful activities.
viii. Legal Compliances and Security Protections: In addition to required disclosures enumerated above, there may be situations where we deem it necessary to disclose personal information to comply with the law or protect the rights, property, or safety of Coral Academy, yourself, or others. Such instances may include, but are not limited to, the following circumstances:
Compliance with legal obligations or requests from individuals with legal authority,
Protection and defense of our rights, property, or the rights and property of our customers or partners,
Maintenance of appropriate security measures, including prevention or cessation of attacks on our computer systems or networks,
Preservation of the personal safety of our customers or the general public,
Mitigation of legal liability.
Furthermore, teachers and partners may have an obligation to report suspected abuse or neglect to local authorities, and we expect full compliance from teachers and partners regarding their individual reporting responsibilities. Additionally, we may also report instances of suspected abuse or neglect as necessary.
4. The Purposes for which your Personal Information may be Disclosed
Any Personal Information gathered about the Customers and Teachers (collectively, “Users”) on our platform may be used for the reasons outlined hereunder.
i. Providing Content and Services through our Website, which involves processes such as communication functions; handling of transactions; identity verification; building of User relationships; facilitation of User-to-User interactions as deemed necessary; and the performance of obligations in relation to the provision of these services and content.
ii. Support and Marketing Optimization on our platform, which involves processes such as responding to the queries and grievances of our Users; sending marketing information and recommendations with maintenance of records for our functional, support, and legal purposes; presenting content as effectively as possible; analyzing usage and activity on our Website; and improving or modifying our Services to enhance the User experience based on said queries, suggestions, grievances, analytical information, and other such direct and indirect feedback mechanisms in relation thereto.
iii. Legal and Security Concerns, which involve processes such as protection of our Services, Property, and User Information from potential security threats; backing up of Services and associated data therein for recovery in the case of exigencies; facilitation of the technical functioning of our Website to keep it unencumbered by fraud and abuse; assurance of compliance with our Policies; reporting of suspected criminal activity; compliance with relevant laws, regulations and contractual obligations; and the protection of our legal rights as a platform.
5. Children’s Privacy
Coral Academy maintains a strong commitment to protecting the information entrusted to us by each Customer. We believe it is essential for every Customer to understand how we utilize the information we collect from them. Please note that, with the exception of freely accessible information and pages that do not require any registrations or identifying details, our Website is not directed toward children under the age of 13, nor do we knowingly collect personally identifiable information from children under the age of 13 through our online platform as such.
Coral Academy's Services are designed to operate without any third-party access to a child's personal information. Our Website does not gather or retain any personal information from children, unless necessary to facilitate the learning process for a student who may be a minor. We are committed to complying with the Children's Online Privacy Protection Act of 1998 ("COPPA"). Furthermore, certain features on our Website may be restricted or provided in a limited form to prevent data collection or sharing from children (typically those under 13 or as required by applicable laws) or to restrict direct interactions between children and adults without their parents’ explicit consent.
6. State-specific Information
This supplemental State-specific Privacy Rights Notice is addressed to those who reside in California, Nevada, or Virginia and use our Website and/or the Services offered through the same - serving as a supplementary addendum to the aforementioned Privacy Policy, which remains applicable insofar as it is not conflicting with the provisions stated herein. Please be aware, however, that you may be requested to verify your identity and residence in accordance with relevant laws when contacting us to exercise your State-specific rights.
Subject to specific limitations, the California Consumer Privacy Act (CCPA) and the California Privacy Reform Act (CPRA) afford California consumers and employees the Right to Know or the ability to request disclosure pertaining to the collection, utilization, disclosure, and sale of their personal information (if any). They also possess the Right to Delete, which encompasses the right to request the deletion, access, or modification of their personal information.
Moreover, Virginia consumers are granted the right to request disclosure regarding the collection, utilization, disclosure, and sale of their information (if any). They can also request the deletion, access, or modification of their personal information.
7. How your Personal Information is Protected
In order to ensure the protection of your personal information against unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have implemented appropriate administrative and technical measures, which include safeguarding the storage and transmission of personal information by us.
Coral Academy follows a strict need-to-know basis when disclosing potentially personally-identifying and personally-identifying information. This information is only shared with employees, contractors, affiliated organizations, authorized third-party service providers, and agents who require access to such information for the purpose of processing transactions on our behalf or facilitating the provision of our Services, and who have moreover agreed to maintain the confidentiality of said information and to not disclose it to others. We undertake all reasonable measures necessary to protect against unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.
However, it is important to note that no method of transmission over the Internet or electronic storage can guarantee complete security. Even as we strive to protect the security of your information and regularly review and enhance our information security measures, there is always a risk inherent in such communication methods. While Coral Academy may be contacted to address any questions about the security of your personal information wherever legally required, it is also your own responsibility to safeguard the security of your account credentials.
Obligation of Users:
You should never disclose your password and ensure that your username, password, and personal credentials used to access Coral Academy are kept confidential to prevent unauthorized access to your personal data. Furthermore, please avoid using the same username and password for other services as you use with us.
Effect and Changes to our Policy
This Privacy Policy is applicable in conjunction with the Terms and Conditions, as well as any other notices, terms, and consents that pertain to the collection, use, and disclosure of your personal information by Coral Academy. We reserve the right to update this Notice to reflect such changes in our information practices and therefore encourage you to review this Notice periodically. Should we materially alter this Privacy Policy in a significant manner that affects the handling or disclosure of your personal data, we will update the policy on the website along with the modified date before the effective date of the changes. If required by applicable law, we will provide you with the opportunity to opt out of these changes through the means notified to you at that time. To the fullest extent permissible under relevant laws, your continued use or access to our Services constitutes your acknowledgment of and tacit consent to any and all such changes.
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