Welcome to eTeacher, a virtual school that offers a variety of online courses (the “Service”). The Service is owned and operated by eTeacher Ltd. (“we”, “us”, “our”, “eTeacher”, the “Company”).
TABLE OF CONTENTS
PERSONAL DATA WE COLLECT AND PROCESS
HOW WE PROCESS AND USE PERSONAL DATA
WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS
INTERNATIONAL DATA TRANSFERS
SECURITY AND DATA RETENTION
ADDITIONAL INFORMATION FOR USERS IN THE EUROPEAN ECONOMIC AREA
YOUR EU RIGHTS IN THE EUROPEAN ECONOMIC AREA
ONLINE NOTICE REGARDING CHILDREN IN THE UNITED STATES – COPPA
PERSONAL DATA WE COLLECT AND PROCESS
We collect information you provide us on an inquiry or upon your registration to a course.
Contact Form Information. When you submit an inquiry about the Service through our Website or on a landing page that you were directed to from an online ad, you will be asked to provide us with your contact information, such as your name, email address, phone number and age. We also automatically collect digital information related to the online ad and the landing page you interacted with, including IP address (and the general location corresponding to the address), information about the ad campaign you were presented, the pages you visited on the Websites and your browser and device type.
Registration Information. The Service is available to registered users only. Registering to the Service is performed with a representative through our sales call-center. We record your conversations with our sales call-center. Our representative will ask you to provide your contact information as well as additional information, such as your child’s name (for registration of minors), school, class, gender, date of birth, place of birth, spoken languages, desired courses, computer device technical information, learning level assessment information (via phone questions), billing information, and days and times of availability. We may also keep records of every request or inquiry you refer to us regarding the Service.
You may enrich your student profile with a description of your personal interests and links to your online profiles on social networks. You also may participate in class forum discussions.
LMS Profile and Course Forums. We operate a Learning Management System (LMS) platform that organizes your user account and course information for you. Within the LMS, you may also choose to voluntarily provide a free-text description of your personal interests and links to your online profiles on social networks for your public profile. You may also post your questions and opinions on the class’s online forum and participate in forum discussions with your classmates.v
You do not have a legal obligation to provide us with the information mentioned above. However, if you do not provide us with certain information, we may not be able to respond to your inquiry or provide you our Services.
We will collect information relating to your achievements and participation in the courses you are enrolled to.
Course Information. Throughout your participation in the courses to which you are enrolled, we will collect information such as attendance and absences from class, metrics of student participation in classes, instructor feedback, notification preferences, your coursework and your achievements. If you are enrolled to a course in which we allocate a license to a course-related tool for you to use (e.g., a film-editing tool), we also will process the licensing information for the license assigned to you.
We record the class sessions, with audio and visual video.
Class Recordings. We also video-record our classes. This records the audio and visual video of the instructor and the course participants.
We collect your filmed or textual feedback if you choose to provide it.
Feedback. If you are a student in one of our courses, then depending on the level of your engagement in the course or the recommendation of the instructor, we may contact you (and in the case of a child, contact their parent) by telephone to tell you about the possibility of providing a filmed review for eTeacher. If you agree, we will collect the filmed review from you.
Alternatively, we may send you an email suggesting that you provide a written review on certain external websites or on one of the eTeacher websites.
In the event of a review from a minor student, written parental consent will be obtained.
We may receive your contact information from a prospective customer that you are acquainted with.
Referrals. When we speak with a prospective customer, we sometimes ask them about acquaintances that they can refer us to, who they believe may be interested in our Service. We then receive the contact information of prospective customers.
We collect information relating to your use of the Service and your interaction with us, as well as your responses to polls and surveys on the Website and the Service.
Analytics and Surveys. When you use the Service, when you are presented with or engage with one of our online marketing campaigns, and when you complete one of our online polls or surveys, we will record and collect certain information in relation to your use of the Service and your interactions with the Service, the campaigns and the polls or surveys including IP address (and the general location corresponding to the address), language settings, type of device and browser, and user ID.
HOW WE PROCESS AND USE PERSONAL DATA
To contact you following your request or inquiry
We use the Contact Form Information to get in touch with you in response to your inquiry and to handle your inquiry. We also use the Contact Form Information to help us determine when we should get in touch with you.
To operate and provide the Service, for course teaching, management and administration, for billing purposes and to prevent fraud.
We use the Registration Information and Course Information to verify your identity and enable your access to the Service; for course teaching, management and administration; to charge you for the course fees; to operate the Service and provide you the e-learning course you enrolled to; and for the provision and delivery of any physical products you purchased from us.
We also use the Registration Information and Course Information to facilitate our internal managerial, archival, administrative and audit activities, and to help us prevent users’ fraudulent, abusive and unlawful uses of the Service.
We process LMS Profile and Course Forum to facilitate student interaction and discussions on course topics.
To provide you customer support and send you administrative notifications.
We use your Registration Information and Contact Information to provide you customer support, send you administrative reminders and notifications by email and SMS, and handle your inquiries effectively.
We use Class Recordings for subsequent access by users enrolled to the class, for quality control and defending and asserting claims on misconduct during class.
We process Class Recordings to allow subsequent access to class sessions by users enrolled to the class, for quality assurance checks and controls and for defending and asserting claims of misconduct during class.
We use Analytics and Surveys information to develop and enhance the Service. We also use it for business administration purposes.
We use Analytics and Surveys information to understand how users interact with the Service so that we can further improve, develop and enhance it. We also use Analytics and Surveys information to adjust the Service and our email communications to users’ preferences. We will use this information to understand the market in which we operate in and for managerial reporting and business planning.
We use Feedback to advertise and promote our Service and brand.
We use Feedback Information for marketing and advertising purposes, to understand our customers’ preferences and improve user experience when using the Service. The Feedbacks are posted on YouTube, on our Website and on third party websites.
We use Referrals to offer our Services to prospective customers. We use Registration Information to create a profile based on your past purchases and email marketing offers tailored to your interests.
We use Registration Information to create a profile based on your past purchases, class presence, and interests, in order to then contact you by email with offers for our Services tailored to your interests.
We use Referrals to contact the prospective customers with offers for our Services.
WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS
We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.
We will share your information with our service providers helping us operate the Service.
We may share your information with our service providers who assist us in operating our business and providing the Service to you, such as our marketing, customer support and sales, teaching instructors, and IT and billing vendors. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes.
LMS Profile, Course Forums and Class Recordings are shared with your classmates and course instructor.
Your LMS Profile and Course Forum discussions are shared with and viewable by all users enrolled to the class as well as the course instructor.
Class Recordings are shared with and viewable by all users enrolled to the class as well as the instructor.
Class recordings may also be shared with course instructors for their training process.
Feedbacks are shared with and viewable by anyone on the Internet.
Your Feedbacks are posted on YouTube, on our Website and on third party websites, and thus are shared with and viewable by anyone on the Internet.
We will use and share information if you violated any applicable law.
If you violated any applicable law, we would use and share information we have about you with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling the violation.
We will share your information if we are legally required.
We will share information we have about you if we are required to do so by a judicial, governmental or regulatory authority.
We will use and share your information if necessary, to assert or defend against legal claims.
eTeacher will use and share your information with relevant authorities and with third parties (such as legal counsels and advisors) if necessary, to defend against or assert legal claims, such as in case our terms of service were violated, or in case of misuse of our Service. We will share your information for the purpose of handling the claim, violation, misuse or breach.
We will share your information if the operation of the Service is organized within a different framework.
If the operation of the Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided that those entities agree to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration.
We are not liable for your use of third-party links accessible from our Website or Service.
While visiting our Website or using the Service, you may be directed via hyperlinks or other means to third-party websites, services and online communities that are not affiliated with us such as Facebook, Twitter, YouTube etc. You may also share your diplomas and developed applications on such third-party platforms. Different rules may apply to the use or disclosure of your information by those third parties and you will be subject to the privacy customs and policies of such third parties. We do not control the privacy policies of third parties and recommend that you review such third parties’ privacy policies prior to sharing your information with them.
Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g., smartphone, tablet, etc.) when you use the internet and visit various websites.
The information that the cookies maintain is read by the website you visit, like our Website. This happens during the session of your visit to the website and when you return to visit it again (these are called ‘persistent’ cookies).
Necessary. Cookies that are strictly necessary for the functioning of the Service. The Service cannot operate properly without these cookies. You can set your device to block or alert you about these cookies, but some parts of the Service may not function properly.
Features. Cookies that are used to support various features of the website, such as surveys and feedback form. These cookies are stored on your device for 365 days.
Marketing. Cookies that help us track our online advertising campaigns and analyze our campaign performance in relation to website visitors. These cookies are stored on your device for up to 365 days.
Statistics. Cookies that help us understand how you and other users interact with our website by collecting data that does not directly identify you. These cookies are stored on your device for up to 2 years.
You can always delete or disable cookies
You can always delete the cookies saved on your device through the settings of your computer browser or device. You can also disable cookies for future use through the settings of your computer browser or device.
INTERNATIONAL DATA TRANSFERS
We may store and process information outside your territory.We will transfer information internationally in accordance with applicable data protection laws.
Information we collect from you will be processed first and foremost in Israel, which is recognized by the European Commission as having adequate protection for personal data and in Europe. Your information will also be processed in Uruguay and the Palestinian Authority, where our sales and service call centers are located, in Saudi Arabia, South Africa and other jurisdictions in the world in which our sales representatives are located, and in the United States, where some of our sales representatives and many of our service providers are located.
If we transfer information about you to other jurisdictions, we will do so using adequate safeguards in accordance with the applicable law.
SECURITY AND DATA RETENTION
We retain your personal information for the extended period we need to operate our business, and thereafter as needed for record-keeping purposes.
We retain personal data for the duration needed to support our business activities and as required by the applicable laws in the countries in which we operate. Thereafter, we will continue to retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our Terms of Service, this Policy and other agreements we have with our users.
We implement measures to secure your Information.
We implement certain measures to reduce the risks of damage, loss of information and unauthorized access or use of information. We implement security and organizational measures to reduce risks of denial of service, and unauthorized disclosure or change of information. We conduct security surveys, implement controls and educate our employees about privacy and cybersecurity risks and the ways to mitigate them. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune against or free from information security risks.
ADDITIONAL INFORMATION FOR USERS IN THE EUROPEAN ECONOMIC AREA
eTeacher is the data controller of the personal data we collect in relation to the Service.
eTeacher is the data controller for the purposes of the personal data we process through the Website and regarding the Service.
Our postal address is:
8 Ahliav Street
Ramat Gan, Israel, postal code: 5252261
Our EU representative is RF PRIVACY MINDERS LTD. You may contact them by email at email@example.com.
eTeacher has appointed an EU Representative based in Cyprus, who you may address if you are located in the European Economic Area to ask any questions about our processing of your personal data, including any requests to exercise your rights provided by the General Data Protection Regulation (EU) 2016/679. You can contact our EU Representative by email at firstname.lastname@example.org, or by postal mail to:
RF PRIVACY MINDERS LTD
10 Patron Street
6051 Larnaca, Cyprus
The legal bases under the GDPR for processing your personal data
The legal basis for using the Contact Form Information to get in touch with you in response to your inquiry and to determine when we should get in touch with you, is our legitimate business interests in prioritizing and responding to inquiries.
The legal basis for processing the Registration Information and Course Information for course teaching, management and administration and for billing purposes is the performance of our contract with you for the provision for the e-learning course or other products sold to you, and steps necessary prior to entering into the contract.
The legal basis for processing the Registration Information and Course Information to facilitate our internal managerial, archival, administrative and audit activities, and to help us prevent users fraudulent, abusive and unlawful uses of the Service, is our legitimate business interests in managing and developing our Service and business and protecting them from fraud and other forms of misuse.
The legal basis for processing LMS Profile and Course Forum to facilitate student interaction and discussions on course topics is our legitimate interests in fostering an active and vibrant e-learning environment for students.
The legal basis for processing your Registration Information and Contact Information to provide you customer support, send you administrative reminders and notifications by email and SMS, and handle your inquiries effectively is our legitimate business interests in promoting your engagement with and active participation in the e-learning course and our legitimate business interests in responding to customer inquiries.
The legal basis for processing Class Recordings to allow subsequent access to class sessions by users enrolled to the class is our legitimate business interest in promoting the e-learning experience of all classmates by assisting classmates who wish to review the course content or make-up a missed class.
The legal basis for processing Class Recordings for class instructors’ training and quality assurance checks and controls is the legitimate interests of eTeacher in ensuring and enhancing the quality of the Service’s e-learning experience and the proficiency of the Service’s instructors.
The legal basis for processing Class Recordings for defending and asserting claims on misconduct during class is to protect the vital interests of the class participants and instructor, and for the legitimate interests of eTeacher in handling claims of misconduct during class.
The legal basis for collecting and processing Analytics Information is our legitimate interests in developing, improving and enhancing the Service and the Website.
The legal basis for collecting and processing Analytical and Surveys information is our legitimate interests in developing, improving and enhancing the Service and Website.
The legal basis for using Feedback is your explicit consent expressed when you voluntarily submit the Feedback.
The legal basis for processing Referrals is our legitimate interests in marketing and offering the Service to new prospective customers.
The legal basis for processing Registration Information to create a profile of your interests, in order to then contact you by email with offers for our Services tailored to your interests, is your explicit consent. If the user registered to the Service is a minor, we will seek their parent’s consent for this. You may revoke your consent at any time via the “Unsubscribe” link enclosed in each marketing communication you will receive from us.
The legal basis for using and sharing your information with authorities or third parties, for the purpose of handling violations of law or to assert or defend against legal claims such as in case our terms of service were violated, or in case of misuse of our Service, is our legitimate interests in protecting our business against violations, as well as protecting the vital interests of others.
The legal basis for sharing information we have about you if we are required to do so by a judicial, governmental or regulatory authority, is the legitimate interests of the authority that seeks the information, our legitimate interests in complying with mandatory legal requirements imposed on us, as well as the protection of the vital interests of others and our compliance with a legal obligation to which eTeacher is subject.
The legal basis for sharing your information in the event of a change in our corporate structure is our legitimate interests in our business continuity.
YOUR RIGHTS IN THE EUROPEAN ECONOMIC AREA
You have the right to access, update or delete your information, obtain a copy of your information, withdraw your consent and object or restrict certain data processing activities.
If you are an individual in the EU you have the following rights under the GDPR, subject to the limitations that the GDPR attaches to these rights:
Right to Access your personal information that we process and receive a copy of it.
Right to Rectify inaccurate personal information we have concerning you and to have incomplete personal information completed.
Right to Data Portability, that is, to receive the personal information that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal information be transmitted directly from us to the service provider you designate.
Right to Object, based on your particular situation, to using your personal information on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defense of legal claims. You may also object at any time to the use of your personal information for direct marketing purposes.
Right to Restrict the processing of your personal information (except for storing it) if you contest its accuracy, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal information and requests instead to restrict its use; if we no longer need the personal information for the purposes outlined in this Policy, but you require it to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.
Right to be Forgotten. Under certain circumstances, such as when the personal information is no longer necessary for the purposes for which they were processed, you have the right to ask us to erase tour personal information. However, we may still process your personal information if it is necessary to comply with a legal obligation which we are subject to under laws in EU Member State, or for the establishment, exercise or defense of legal claims.
If the legal basis for processing your personal information is consent, you may withdraw your Consent at any time. If you do that, we will still process certain information on legal basis other than consent, as described in the Policy. Withdrawing your consent will not affect the lawfulness of data processing we carried out based on your consent before such withdrawal.
If you wish to exercise any of the abovementioned rights, contact us at Privacy@eteachergroup.com.
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason why.
You have a right to submit a complaint to the relevant supervisory data protection authority.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
You must be at least 18 years of age or have parental consent to use the Service.
The Service includes courses that are intended for children under 18. If a child under 18 wishes to register for the Service, we will require parental consent for the collection and processing of the child’s information.
ONLINE NOTICE OF INFORMATION PRACTICES REGARDING CHILDREN IN THE UNITED STATES – COPPA
This section describes the Service’s information practices regarding information collected from children under 13 in the United Stated who are enrolled in online courses on the Service. It is provided to you according to the U.S. federal Children’s Online Privacy Protection Act and its regulations (COPPA). This notice applies to information collected from the child’s use of the Service in respect of the course he or she is presently enrolled to, and in respect of courses he or she may be enrolled to in the future.
Operators collecting or maintaining personal information from children through the Service
The following are operators who help us in the internal operation of the Service and who in doing so collect or maintain personal information from the children who use the Service:
1. Zoom Video Communications Inc.
2. WhatsApp Inc.
3. Amazon Web Services, Inc.
4. Gerymoll S.A. – Telecom Networks
5. MeisterLabs GmbH
6. Microsoft Corporation
7. OwnCloud GmbH
8. Intelitek, Inc.
9. ActiveCampaign, LLC
For inquiries from parents concerning the operators’ privacy policies and use of children’s information, please contact us through the channels listed below.
Information we collect from children and the ways we use it
We collect the following information from children, for the purposes explained below:
• During our onboarding call with the parent, we may, with the parent’s permission, speak with the child to obtain information regarding the child’s level of knowledge and skills in order to assess his or her suitability for a given course level.
• In response to technical or customer support requests by the child, we may obtain information to identify the child as an enrolled student (such as his or her first and last name), as well as technical information regarding the computer device that the child uses when interacting with the Service. This may include the device type and operating system and the device’s IP address. This information is used for the purpose of technical support and internal operation and administration of the Service.
• When the child logs on to an online lesson, he or she is asked to provide an email address. The email address is used only for the purpose of internal operation and administration of the Service.
• When the child logs to an online lesson, he or she is asked to provide a name or nickname. The name or nickname entered is presented to all other lesson participants during the lesson and is shown on the lesson’s recorded footage.
• At the child’s choice, he or she may enter chat messages on a lesson’s chat environment, which is presented to all other lesson participants during the lesson. When the child speaks during a lesson, whatever he or she says is heard by all other lesson participants during the lesson and is collected into the lesson’s recorded footage. The purpose of the footage is to allow subsequent access to class sessions by users enrolled to the class, for quality assurance checks and controls and for defending and asserting claims of misconduct during class.
• When the child presents his or her coursework during a lesson, his or her web cam feed or screenshare is presented to all other lesson participants during a lesson and is collected into the lesson’s recorded footage.
• At the child’s choice, he or she may add a profile image to his or her profile page on the Service. The image is used only for the purpose of maintaining the child’s profile page. As a parent, you may block your child uploading a profile image through your privacy settings dashboard on our Learning Management System (LMS).
• At the child’s choice, he or she may publish posts on the course’s forum. In addition, the child may upload files to a shared environment and can create brainstorming mind maps on MindMeister. The content of such posts, uploads, and mind maps, which may include personal information, is determined by the posting child. The posts, uploads and mind maps are used for the purpose of the course. Note that as a parent, you may block your child ability to post on the course’s forum through your privacy settings dashboard on our Learning Management System (LMS).
• The child receives the email address and telephone number of the course’s instructor. When the child communicates with the course’s instructor, he or she, at their choice, may communicate personal information concerning him or herself. That information is only used for the purpose of course instruction and administration.
• The child’s attendance information for the course and information concerning the child’s viewership of course materials. This information is used only for course instruction and administration purposes.
Enabling the child to make personal information publicly available
The child may make personal information available to the child’s fellow peers on the course in the following instances:
• The child’s name, his or her lesson chat messages, web cam feed, screen-share and voice feed, as explained above. These are exposed to all lesson participants during the lesson and afterwards, by those accessing the lesson’s recorded footage.
• Profile image that the child adds to his or her profile on the Service (if not blocked from doing so through the parent’s privacy settings dashboard).
• Posts published by the child on the course’s forum (if not blocked from doing so through the parent’s privacy settings dashboard).
• Files uploaded by the child to the shared environment of the course.
• Mind maps created by the child.
To whom we disclose information we collect from children
The information outlined above in “Enabling the child to make personal information publicly available” is disclosed to the child’s fellow peers on the course.
Parental rights regarding the information we collect from children
As a parent, you may review or have the child’s personal information deleted. You may also refuse to permit further collection of the child’s information. In that case, we will remove your child from the course and block him or her from participating in the course.
To exercise any of these rights, contact us through any of the channels listed below.
If we change this Policy, we will provide you with notice of such change.
From time to time, we may change this Policy, in which case we will inform you of the updated Policy through the Service’s interface or via the email address you provided us. The latest version of the Policy will always be accessible through the Website.
Should you have any inquiries, complaints or suggestions, you may contact us at Privacy@eteachergroup.com or through any of the other channels listed at https://www.eteachergroup.com/contact-us/. We will do our best to respond in a timely manner.
Last Update: June 14, 2021.