Privacy Policy | Dearest
November, 2020
Welcome to www.dearest.io (the “Site”) of Dearest, Inc. (“Dearest”).

 Dearest is a service that allows parents or guardians to book tutoring, online tutoring, pod-sessions and in-person educational care

, and for educators to publicize, and provide these sessions (the “Services”).
This Privacy Policy outlines Dearest’s policy with respect to the information collected from visitors and users of the Dearest Services. Your access to and use of our Services is subject to the Terms of Service. Terms not defined in this Privacy Policy have the meaning as set forth in the Terms of Service for the Services, which can be found at https://www.dearest.io/terms-and-conditions.
If you are visiting us from the European Union or European Economic Area, please be sure to read the section entitled “Additional Information for Users in the European Economic Area” for information on how we comply with privacy laws applicable to you.
Information we collect
When you interact with us through the Services, we may collect information that, alone or in combination could be used to identify you (“Personal Data") and other information from you, as further described below:
Personal Data That You Provide Through the Site:
We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries or register for a Dearest account to access the Services.
We may collect the following information from you in order to provide our Services:
- name or publicly posted name from a Facebook linked account;
- email address;
- phone number;
- address;
- zip code or city and state you are located in;
- credit card or other payment information;
- your child’s name;
- your child’s age or birthday;
- your child’s email address;
- video recordings and pictures of your child during classes/sessions;
- learning reports about your child during classes/sessions, created by the Educator.
- your voluntarily provided profile picture or your Facebook picture linked to your account;
- information voluntarily provided of your profile;Information voluntarily provided through reviews;
- and messages and notes you provide to educators about yourself or your child
By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to our Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Dearest and the authorized third parties referred to herein.
Other Information:
Passively Collected Data: When you interact with us through the Site, we receive and store certain data automatically. Dearest may store such passively collected data itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Sites and the domain names of our visitors' Internet service providers.
In operating our Sites, we and third parties that provide certain functionality to the Dearest Services may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Site. Our cookies help provide additional functionality to our Services and help us analyze Site usage more accurately. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of our Services’ features. For more information about our use of cookies, please see the section entitled “Cookie Policy,” below.
Aggregated Personal Data:
‍We may aggregate data, including Personal Data, and use such aggregated data for any purpose. This aggregate information does not identify you personally.
Our use of Personal Data and other information
‍We use your information to:
- provide the Dearest Services;
- process your payment for the Services;
- send you emails or newsletters that you signed up for;
- improve the Dearest Services;
- and analyze website usage
Dearest Educators may receive recordings of their classes and may use the recording to improve their curriculum and classes and may provide the recording to Parents and the participants in the class to view. Dearest and its affiliates may use your Personal Data to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each promotional communication we send you will contain instructions permitting you to "opt-out" of receiving future promotional information. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us at support@dearest.io. Please note that we will continue to contact you via email to respond to requests and provide our Services.
Storing data
‍Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Our disclosure of Personal Data and other information
‍We may share your Personal Data with certain third parties without further notice to you, as set forth below:
Business Transfers:
‍ If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred to a successor or affiliate alone or as part of that transaction along with other assets.
Vendors and Service Providers:
‍ We engage third party vendors and service providers to perform certain functions on our behalf (such as payment processing). These third parties may have limited access to databases of user information or registered member information solely for the purpose of helping us to provide and/or improve the Services and they will be subject to contractual restrictions prohibiting them from using the information about our Users for any other purpose. Such agents or third parties do not have any rights to use Personal Data beyond what is necessary to assist us.
Legal Requirements:
‍ ‍Dearest may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Dearest, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
Publicly posted information
‍You may be able to share Personal Data with third parties, including with the general public, through use of the Services.
User Profile:
‍ ‍As a user of our Services, you will have a user profile that will be publicly available to all users of the Services (the “User Profile”). You are not required to include any Personal Data on your User Profile. But you will have the option to include a variety of types of Personal Data in your User Profile, which may include your first name, last name, biographical information, geographical location, and personal photograph.We do not systematically monitor the content of information that is published on your user profile. Any information published in your User Profile may become available to the public. After publishing, we have no control over how such information is used or its further dissemination. We urge you to think carefully about what, if any, Personal Data you include in your User Profile.
Dashboard and Forums:
‍ ‍Our Services may provide you the opportunity to share information (for example, your child's projects) with other Dearest Users through dashboard and forums (the “Dashboard and Forums”). Use of the Dashboard and Forums is entirely voluntary. But please be aware that any information you place on Dashboard and Forums will become available to all Dearest Users without restriction.
‍ We do not systematically monitor the content of information that is published in the Dashboard and Forums. Any information published in Dashboard and Forums becomes available to the public. After publishing, we have no control over how such information is used or its further dissemination. We urge you to think carefully about what, if any, Personal Data you include in your posts on our Dashboard and Forums.
Children
‍This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by children under the age of 13 (“Child” or “Children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding Children’s personal information. For more information about COPPA and general tips about protecting Children’s online privacy, please visit OnGuard Online.
Collection:
‍ ‍Dearest collects information about students directly from Parents, who provide us with the Child’s first name, age, type of schooling, location, and additional notes for the Educator. In addition, Children may share information about themselves during online sessions. The Dearest sessions may take place over online videos in which video images and audio of the Children are recorded. No information is collected directly from Children until they are in the course session. Children cannot post personal data publicly on the Dearest Services.
Use and Disclosure:
‍ ‍Dearest shares the name, age, location, and any notes Parents have provided about their Child to the Educator, in order to allow the Educator to provide Classes. This information shall also be treated as part of the Parent’s Personal Data and may be shared as described in the Disclosure section above for business transfers; to vendors and service providers; and to comply with legal requirements. Children may also share information about themselves with the Educator and the rest of their class during the Session voluntarily. While Dearest expects Educators and all others Users to abide by our standards of conduct, please note that we cannot control or monitor what personal information your Child shares with Educators or other classmates, nor what those third parties ultimately do with that information, and disclaim all responsibility in that regard.
Session Video Recordings:
‍ ‍‍As described above, Dearest may record video of students and Educators during Dearest sessions (“Session Recordings”). The Session Recordings are made available by Dearest to the Educator of the Class and may be shared by the Educator for the entire class (and their Parents) to view (the “Permitted Recipients”). Dearest may also use Session Recordings to provide feedback to Educators, for customer support, and for compliance purposes. Dearest will obtain additional parental consent before we use any Session Recordings for promotional or other purposes. We utilize reasonable means to (i) limit the ability of Educators to create copies of the Session Recordings or to share the Session Recordings with anyone aside from Permitted Recipients, and also (ii) limit the ability of Permitted Recipients to download or re-share the Session Recordings. While we expect Educators and Permitted Recipients to abide by our standards of conduct, please note that we cannot control or monitor what such third parties ultimately do with Session Recordings, and disclaim all responsibility in that regard.
Parental Consent:
‍ Dearest obtains verifiable parental consent before collecting Personal Data from your Child. Dearest requires that you provide your credit card information in order to register your Child for and pay for a Dearest Services. If you do not consent, then we will not collect, use or disclose any personal information about your Child, and your Child will not be allowed to use the Services in any way.
Parental Choices and Controls:
‍ At any time, you can refuse to permit us to collect further Personal Data from your Children in association with your account, and can request that we delete from our records the Personal Data we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You may update your Child’s information by logging onto your account. You can contact Dearest to request access to, change, or delete your Child’s personal information by sending an email to us at support@dearest.io. A valid request to delete personal information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal information belonging to Children when it is no longer needed for the purpose for which it was collected.
Links to other websites
‍This Privacy Policy applies only to the Dearest Services. The Services may contain links to other websites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we describe here do not apply to the Third Party Sites. The links from our Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
Social media
‍‍When you log into the Site using your Facebook account, we will collect relevant information necessary to enable us to access your Facebook account; however you will provide your login information, like your password, directly to Facebook (and not to Dearest). As part of such integration, Facebook will provide us with access to certain information that you have provided to Facebook, and we will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of Facebook. However, please remember that the manner in which Facebook uses, stores and disclose your information is governed by the policies of Facebook, and, as a result, Dearest shall not have any liability or responsibility for the privacy practices or other actions of Facebook that may be enabled within and/or otherwise accessible through our Services.
‍Security
‍‍‍We take reasonable steps to protect the Personal Data provided via the Services from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, the Internet cannot be guaranteed to be fully secure and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for disclosures beyond our reasonable control. You are also responsible for helping to protect the security of your account credentials. For instance, never give out your password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Data. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.
‍Do Not Track
‍Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. While we do not currently support Do Not Track signals, we treat the data of everyone who comes to our site in accordance with this Privacy Policy, whatever their Do Not Track setting.‍‍‍
‍Access and accuracy
‍You have the right to access the Personal Data we hold about you in order to verify the Personal Data we have collected with respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Data, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. We will make every reasonable effort to keep your Personal Data accurate and up-to-date, and we will provide you with mechanisms to correct, amend, delete, or limit the use of your Personal Data. As appropriate, this amended Personal Data will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Data about you enables us to give you the best possible service.‍‍‍
‍ In certain circumstances, you have the right:
‍ - to access and receive a copy of the Personal Data we hold about you;
‍ - to rectify any Personal Data held about you that is inaccurate;
‍ - to request the deletion of Personal Data held about you
‍ You have the right to data portability for the information you provide to us. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
‍ Please note that we will ask you to verify your identity before responding to such requests.
‍Cookie Policy
‍We use your IP address to help diagnose problems with our server, to administer our Services, and to analyze traffic patterns on the Services. The Services also use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Site and Services, to analyze trends, learn about our user base and operate and improve our Services. For example, we use Cookies to deliver content specific to your interests, to save your password so you don't have to re-enter it each time you visit, and to track whether emails we send you have been viewed. Cookies are small files placed on your computer, tablet, phone, or similar device when you use that device to visit our Site. We sometimes combine information collected through Cookies that is not Personal Data with Personal Data that we have about you, for example, to tell us who you are or whether you have an account with us. We may also supplement the information we collect from you with information received from third parties.‍‍‍
‍ Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting our Site or using our Services, whereas “persistent Cookies” are stored on your device for a period of time after you leave our Site or Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Services, how often you return, how your use of the Services may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Services. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Because we collect browsing and persistent identifier data, the Services do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave our properties.
‍ Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Site or Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies.
We use the following types of Cookies:
‍ ‍‍1. Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Site or Services. Disabling these Cookies may make certain features and services unavailable.
‍ 2. Functionality Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
‍ ‍‍3. Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Site and Services such as by collecting information about the daily number of visitors to the Services, the daily requests we receive for particular files on the Services, and what geographical areas those requests come from. These aggregated statistics are used internally to better provide services to the public and may also be provided to others. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google's use of cookies by visiting the Google advertising opt-out page at https://www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
‍ 4. Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
‍ You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Services and functionalities may not work.
‍ To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find our more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/or http://www.allaboutcookies.org/.
‍‍Changes to our Privacy Policy
‍We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted, and any material changes will become effective 30 days from their posting on this page or via email to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Personal Data that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.
‍‍‍Contact us
‍Please feel free to contact us if you have any questions about Dearest’s Privacy Policy or the information practices of our Services.You may contact us as follows: You may send an email to privacy@dearest.io‍‍‍.
‍‍‍California Privacy Rights
‍‍California Civil Code Section 1798.83 permits users of the Services who are California residents to request certain information regarding its disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email with ‘California Privacy Rights’ in the heading to privacy@dearest.io‍‍‍ or write us at the address listed below.
‍‍‍Additional Information for Users in the European Economic Area
Personal Information
‍ ‍‍References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
‍Controller
‍ ‍‍Localize Corporation is the controller of your personal information for purposes of European data protection legislation.
‍‍Lawful Basis for Data Processing
‍ ‍‍‍We will only collect, store, and process your personal information where a lawful basis for such processing exists, which will typically fall under one of the following scenarios:You, the Data Subject, have given consent to the processing of your personal information for one or more specific purposes, for example by consenting to terms and conditions on our website, and consenting to the terms of this Privacy Notice;Processing is necessary for the performance of a contract to which you, the Data Subject, are party;Processing is necessary for compliance with a legal obligation to which we as a Controller is subject;Processing is necessary for the purposes of the legitimate interests pursued by us as the Controller, or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you, the Data Subject, which require protection of your personal information. The legitimate interests that underlie our processing of personal data include research and development, marketing and promoting the Services, and protecting our legal rights and interests.
‍‍Use for new purposes
‍ ‍‍‍‍We may use your personal information for reasons not described in this Privacy Notice where permitted by law and the reason is compatible with the purpose for which we collected it.
‍‍‍Retention
‍ ‍We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For example, we keep account information for as long as the account is active, and for a reasonable period thereafter to ease reactivation if you choose to reactivate your account. If the Services are made available to you through an organization, e.g., your employer, we retain your information as long as required by the administrator of your account on their behalf.
‍ To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
‍‍‍‍Your rights
‍ ‍European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
‍ ‍“Opt-out”. Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.
‍ ‍“Access”. Provide you with information about our processing of your personal information and give you access to your personal information.
‍ ‍“Correct”. Update or correct inaccuracies in your personal information.
‍ ‍“Delete”. Delete your personal information.
‍ “Transfer”. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
‍ ‍“Object”. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
‍ ‍“Withdraw Consent”. If our processing is based on your consent, you have the right to withdraw such consent at any time.
‍ ‍You can submit these requests by email to: privacy@dearest.io‍‍‍. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described in the preceding section of our Privacy Policy or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
‍‍‍Cross-Border Data Transfer
‍ ‍‍Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on either use of approved standard contractual clauses or one of the safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation.