Effective Date: August 28 2023

This Privacy Policy (“Policy”) describes how Verbaroo (“we”, “our”, or “us”) collects, uses, and protects personal information obtained from Users of the verbaroo.com website (“Website”) and our services (“Services”). By accessing or using the Website and Services, the User consents to the collection, use, and disclosure of the User’s personal information as described in this Policy. If the User does not agree with this Policy, please refrain from using the Website and Services.

1. Definitions

1.1 “User” refers to any individual or entity that accesses or uses the Website and Services.

1.2 “Employer” refers to businesses or organizations that enroll their employees for our Services.

1.3 “Employee” refers to individuals enrolled in Verbaroo courses by their Employer.

1.4 “Consumer” refers to individuals who register for classes or services on their own behalf, independent of any employer-sponsored arrangement.

1.5 “Instructor” For the purposes of this Agreement, the term “Instructor” refers to any individual engaged by Verbaroo to provide English language training services to users, whether they are employees, contractors, or affiliates of Verbaroo. An Instructor is responsible for delivering lessons, assessing user progress, and providing feedback in accordance with Verbaroo’s guidelines and standards. The term “Instructor” is synonymous with “tutor” as used in other contexts but is aligned with the terminology presented on Verbaroo’s webpages.

1.6 “Website” refers to verbaroo.com, a website owned and operated by Verbaroo. The Website provides a platform for language learners to access the Services, including online language courses, communications with instructors, and administrative staff.

1.7 “Services” The term “Services” encompasses the provision of online language courses, communications with instructors, and administrative staff. These Services are intended for language learners to connect with instructors, facilitate the learning process, and interact with administrative staff.

2. Information Collection

2.1 Personal Information: We may collect personal information about Users, including both Employees and Consumers, when they register on the Website, use our Services, or provide information voluntarily. This may include their name, email address, contact details, payment information, and other relevant information necessary for the provision of our Services.

2.2 Data Usage: We may also collect non-personally identifiable information about the User’s use of the Website and Services, such as the User’s IP address, browser type, device information, and usage patterns. This information helps us improve the performance and functionality of our Website and Services.

3. Use of Information

3.1 Service Provision: We may use the User’s personal information to:

a) Provide the Services, including lesson scheduling, connecting with instructors, and facilitating communication.

b) Process payments for our Services through our third-party payment processor, Stripe, in accordance with their terms and privacy policy.

c) Respond to the User’s requests, inquiries, or customer support needs.

d) Enhance and personalize the User’s experience on the Website and Services.

e) Send the User administrative or promotional communications related to our Services.

3.2 Legal Basis: We process the User’s personal information based on the following legal grounds:

a) Contract Execution: Processing is necessary for the performance of the agreement or understanding between the User and us, including the provision of the requested Services. This “agreement” or “understanding” refers not only to traditional written contracts but also to digital agreements, terms of service, or any other form of consent that the User provides when using our Services. For instance, when a User agrees to our terms and conditions on our website or app, they are entering into an agreement with Verbaroo, allowing us to process their personal information to deliver the services they’ve requested.

b) Legitimate Interests: We have a legitimate interest in operating and improving our Website and Services, as well as marketing and promoting our offerings. We ensure to protect the User’s privacy rights and minimize any impact on the User’s rights and interests.

c) Legal Obligations: We may process the User’s personal information to comply with applicable laws and regulations.

d) Non-sale and Non-rental of Personal Information: We do not sell or rent the User’s personal information to anyone, including third-party services with which we are associated.

4. Employee and Employer Information Confidentiality

4.1 Confidentiality of Job-Related Conversations: All conversations, communications, and information pertaining to an Employee’s job, role, or professional responsibilities, whether shared by the Employee or the Employer, shall be treated with the utmost confidentiality by Verbaroo. Such information shall not be disclosed, shared, or otherwise made available to third parties without the explicit consent of the Employee or Employer, as applicable.

4.2 Proprietary Lessons and Materials: Lessons, training materials, and any related content provided to an Employee through our Services are proprietary and confidential. They shall not be shared, reproduced, or disseminated to third parties, including other Employees or Employers, without the express written consent of Verbaroo.

4.3 Non-Disclosure of Sensitive Information: Users, whether acting in the capacity of employees or individual consumers, are strictly prohibited from disclosing any confidential, proprietary, or sensitive information pertaining to their respective business or employer during tutoring sessions, lessons, or in any form of communication with Verbaroo instructors, tutors, or staff members.

4.4 Employer’s Responsibility: It is the express obligation of the Employer to ensure that their employees, representatives, or agents are fully aware of and comply with this provision. Employers are advised to provide clear instructions to their employees regarding the boundaries of information sharing with Verbaroo.

4.5 Indemnification: In the event of a breach of this clause, whether through intentional or unintentional disclosure of such sensitive information by an employee, consumer, or any User, the Employer and/or User agrees to indemnify and hold harmless Verbaroo, its officers, directors, employees, and agents from any and all resultant claims, actions, demands, liabilities, judgments, and settlements, inclusive of, but not limited to, reasonable legal and accounting fees arising from or alleged to have arisen from such unauthorized disclosure.

5. Data Retention and Security

5.1 Retention: We retain the User’s personal information for the duration necessary to achieve the objectives described in this Policy, or as required by applicable legal and regulatory requirements. The retention period may vary depending on the nature of the information and legal obligations.

5.2 Security: We take reasonable measures to protect the User’s personal information against unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure. Therefore, we cannot guarantee the absolute security of the User’s information.

6. Third-Party Service Providers

We may engage third-party service providers to assist us in the operation and improvement of our Website and Services, such as payment processors, cloud hosting providers, analytics services, and transactional email services. These providers may have access to the User’s personal information but are required to treat it confidentially and securely, in accordance with their own privacy policies and applicable data protection laws.

7. Use of Cookies

Verbaroo (“We”, “Our”) and our third-party service providers, which include but are not limited to Calendly, SureCart, and Stripe (collectively, “Service Providers”), use cookies and similar tracking technologies on our website in compliance with applicable local, regional, and international laws and regulations.

Cookies are small data files that are placed on the User’s device when the User visits our website. These cookies allow us to remember the User’s preferences, enhance the User’s user experience, and monitor our website’s performance.

Our Service Providers also use cookies and similar tracking technologies to provide us with certain services. For example, Calendly uses cookies to facilitate lesson scheduling, while SureCart and Stripe use cookies to process credit card payments.

We, along with our Service Providers, commit to complying with legal requirements and best practices in our use of cookies and similar tracking technologies.

By using our website, the User consents to the use of cookies and similar tracking technologies in accordance with this policy.

8. Third-Party Marketing

We do not share, sell, rent, or trade the User’s personal information with third parties for their promotional purposes.

9. Business Transfers

In the event of a merger, acquisition, bankruptcy, dissolution, reorganization, or similar event, we may transfer or share the User’s personal information with a third party involved in such event.

10. International Data Transfers

10.1 Secure and Compliant Transfers: At Verbaroo, we recognize the importance of safeguarding our Users’ personal information, especially when it traverses international borders. While the nature of our digital services may necessitate the transfer, storage, and processing of personal information in countries other than the User’s country of residence, we take meticulous measures to ensure these actions are conducted with the utmost security and integrity.

10.2 Adherence to Global Standards: We are committed to upholding high international standards for data protection. Any data transfer we initiate or facilitate is in strict compliance with recognized data protection principles and laws. This means that any third-party service providers or partners we collaborate with are vetted to ensure they provide equivalent levels of data protection.

10.3 Business-Centric Approach: We understand that our Users trust us with their professional and personal information. Our international data transfer practices are designed not just for compliance but to uphold that trust, ensuring that your business interactions with Verbaroo remain seamless, secure, and always in the best interest of your professional growth.

11. California Consumer Privacy Act (CCPA) Rights (For California Residents)

If the User is a resident of California, the User has certain rights under the CCPA, such as the right to know what personal information is collected, the right to delete personal information, and the right to opt-out of the sale of personal information. Please contact us to exercise these rights.

12. Consent Withdrawal

The User has the right to withdraw consent to the processing of the User’s personal information at any time. Please note that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

13. Automated Decision Making

We do not use the User’s personal information for automated decision-making, including profiling, without the User’s explicit consent.

14. Data Breach Notification

In the event of a data breach that affects the User’s personal information, we will notify the User and the relevant authorities within 72 hours of becoming aware of the breach, in accordance with applicable laws.

15. Dispute Resolution

If the User has any complaints regarding our privacy practices, the User can contact us, and we will work with the User to resolve the issue. If we cannot resolve the issue, the User has the right to lodge a complaint with a supervisory authority.

16. Children’s Privacy

Our Website and Services are not intended for children under the age of 18. We do not knowingly collect personal information from children. If the User discovers that a child has provided us with personal information without parental consent, please contact us, and we will take appropriate measures to delete the information and terminate the child’s account.

17. Your Rights

The User has certain rights regarding the personal information we hold about the User, subject to applicable laws. These rights may include the right to access, correct, update, or delete the User’s personal information. To exercise these rights, please contact us using the information provided in Section 19.

18. Changes to this Privacy Policy

We reserve the right to modify or update this Policy at any time, at our sole discretion. We will inform the User of any significant changes by posting the updated Policy on the Website or through other communication channels. The User’s continued use of the Website and Services after the effective date of the revised Policy constitutes the User’s acceptance of the updated terms.

19. Contact Us

If the User has questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at the following address: info@verbaroo.com.

Please read this Privacy Policy carefully to understand how we process the User’s personal information. By using the Website or accessing our Services, the User acknowledges that the User has read, understood, and agreed to be bound by this Privacy Policy.