PONDDY PRIVACY POLICY
LAST UPDATED: August 18, 2020

Ponddy Education, Inc. (“Ponddy”, “we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy applies to: (i) the Ponddy Reader Platform (which includes any and all underlying software and technology); (ii) the Ponddy Tutors Platform (which includes any and all underlying software and technology); (iii) the website owned or operated by Ponddy located at http://reader.Ponddy.com (“Ponddy Reader Website”); and (iv) the website owned or operated by Ponddy located at http:/tutors.Ponddy.com (“Ponddy Tutors Website”); (v) any other Ponddy Platform products or services (clauses (i)-(v) collectively referred to as, the “Ponddy Services”) offered by Ponddy to you, the user of the Ponddy Services (“you” or “your”). This Privacy Policy is a part of and incorporated into the Ponddy Reader Terms of Service and Ponddy Tutors Terms of Service (in this document, collectively called the “TOS”). If any provision of this Privacy Policy is inconsistent or conflicts with any provision in the TOS, this Privacy Policy will control with respect to the subject matter of this Privacy Policy. Capitalized terms used in this Privacy Policy but not defined in this Privacy Policy have the meanings given to them in the TOS. This Privacy Policy is intended to inform you about the kind of information, including personally identifiable information, that we may collect about you in connection with your use of the Ponddy Services and how, and for what purpose, we use that information.
This Privacy Policy is intended to inform you about the kind of information, including personally identifiable information, that we may collect about you in connection with your use of the Ponddy Services and how, and for what purpose, we use that information.
YOU GIVE US CONSENT
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use or access the Ponddy Services. By accessing or viewing the Ponddy Services, or submitting Personal Information through the Ponddy Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use, and disclosure of your Personal Information and Anonymous Information in accordance with this Privacy Policy. You understand that by providing us Personal Information, you allow us to identify you. Some of the services we provide may not be available if you do not provide us the necessary Personal Information.
PERSONAL INFORMATION v. ANONYMOUS INFORMATION
We collect both Personal Information and Anonymous Information, each as defined below, in connection with your use of the Ponddy Services.
YOU GIVE US CONSENT
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use or access the Ponddy Services. By accessing or viewing the Ponddy Services, or submitting Personal Information through the Ponddy Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use, and disclosure of your Personal Information and Anonymous Information in accordance with this Privacy Policy. You understand that by providing us Personal Information, you allow us to identify you. Some of the services we provide may not be available if you do not provide us the necessary Personal Information.
Personal Information” is information that allows someone to identify or contact you, as well as any other non-public information about you that is associated with or linked to any of the foregoing, and can include, for example, an individual's first and last name, phone number, and e-mail address.
Anonymous Information” means information that is not associated with or linked to your Personal Information; Anonymous Information does not, by itself, permit the identification of individual persons.
PROTECTING YOUR PRIVACY
We do not share, rent or sell your account information to any third party, except as expressly set forth in this Privacy Policy. Please help us protect your privacy by keeping your account information safe. Do not disclose your account password or logon information to anyone and keep changing your password periodically. If you find that an account depicting your personal or business profile or information has been created on the Ponddy Services by an unauthorized individual, please contact us immediately at support(at)ponddy-edu(dot)com to request for its removal.
INFORMATION WE COLLECT AND HOW WE USE IT
Registration Information
When you register an account with the Ponddy Services, you are required to provide us Personal Information. We collect and store the following Personal Information in connection with the registration of an account: your first and last name, email, year of birth, gender, phone number, state and country of residence, and name of school (if applicable).
We may use the Personal Information you submit during the registration process to provide the Ponddy Services and send you services-related communications. We may also use such Personal Information to send you electronic newsletters or promotional e-mails, unless you have requested not to receive such promotional communications from us as described below. Ponddy also uses this information to understand user’s needs and interests and to better tailor the Ponddy Services to meet your needs and interests.
Account Information
You may provide information to customize or enhance your user account, such as, full date of birth, additional contact information, and your hobbies and interests.
If you provide information to customize or enhance your user account, we will use such information to provide you with better matching services and/or content. Ponddy also uses this information to understand user’s needs and interests and to better tailor the Ponddy Services to meet your needs and interests.
Payment and Billing Information
When you submit payment through the Ponddy Services, our third party payment processor will collect, on our behalf, your name, billing address, and complete credit card information, or your bank account information.
Our payment processing service provider will retain this information to process your payments to pay for Content Offerings or a Subscription, as applicable.
Feedback and Communications
If you provide us Feedback or contact us via e-mail or participate in our surveys, we will collect your first and last name and e-mail address, any information requested in our Feedback or polling forms, as well as any other content included in the e-mail or Feedback and polling forms you send to us. Any Feedback you provide will be governed by the TOS.
We may use Personal Information submitted in your communications to contact and respond to you. Ponddy also uses information in Feedback to understand user’s needs and interests and to better tailor the Ponddy Services to meet your needs.
Log File Information
When you register an account with or access the Ponddy Services, our service provider may collect, and share with us, information such as your web request, IP address, access times, and other browsing information.
This information is used to provide you the Ponddy Services and other services requested by you, improve the Ponddy Services and other services provided to you by us, customize the content and layout for each individual user, notify user about updates to the Ponddy Services, and contact you for our own internal marketing purposes.
Cookies
A cookie browser is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Ponddy Services. Unless you have adjusted your browser setting so that it will refuse cookies, the Ponddy Services will issue cookies when you direct your browser to the Ponddy Services. You can remove cookies by following directions provided in your Internet browser’s help file, provided, however, that by doing so, you may not be able to utilize some functions of the Ponddy Services. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Certain features of the Ponddy Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on the Ponddy Services, such as, keeping track of your purchases or shopping cart, storing your login name and password, and click stream data.
Web Beacons
Pages within the Ponddy Services (including, the Ponddy Reader Website and Ponddy Tutors Website) and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain content and verifying system and server integrity).
Information gathered from web beacons is used to enable more accurate reporting, improve the effectiveness of our marketing, and improve the Ponddy Services. We do not use web beacons to store or link to Personal Information.
Anonymous Information
We may create Anonymous Information records from Personal Information by excluding information (such as your name) that would otherwise make such data personally identifiable to you. We may use Anonymous Information at our discretion and for any purpose. We may share Anonymous Information with the public or partners, for example, by providing or conducting research about how users learn. When we provide or use this information, we employ procedures so that the data does not identify you and we prohibit recipients of the data from manipulating the data in a way that would re-identify it back to you.
Collection by Third Party Tools
The Ponddy Services may also contain third party tracking tools from our service providers (for example Google Analytics). Such third parties may use cookies and application programming interfaces on our Ponddy Services to enable them to collect and analyze user information on our behalf.
User Content and Content Offerings
You may also provide information by posting User Content or listing a Content Offering on public areas of the Ponddy Services. Your User Content and Content Offering are transmitted to others at your own risk. We cannot control the actions of other users of the Ponddy Services with whom you may choose to share your User Content or Content Offering. Therefore, we cannot and do not guarantee that your User Content or Content Offering will not be viewed by unauthorized persons.
HOW WE SHARE YOUR INFORMATION
We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Information with certain third parties without further notice to you, as set forth below.
Services Providers
We may provide your information to third party service providers (such as, but not limited to, our cloud service provider and payment processors) who need the information to perform services for us. These third party service providers are required not to use your Personal Information other than to provide the services requested by Ponddy.
Affiliates
To provide the Ponddy Services and various services to you, we may use the efforts of its parent company, and any subsidiaries, joint ventures, or other companies, existing or formed in the future, under a common control (collectively, “ Affiliates”). We may share some or all of your Personal Information with our Affiliates in which case we will require our Affiliates to comply with this Privacy Policy.
Business Transfers
As we develop our business, we might sell or buy businesses or assets. In the event we are acquired by or merged with a third party, we reserve the right to transfer or assign the information we have collected from our users as a part of such merger, acquisition, sale, or other change of control. In the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors’ rights generally, your Personal Information may be transferred by the trustee. If Ponddy or any of its Affiliates is acquired by or merged with a third party, that third party will possess the Personal Information in Ponddy’s or its Affiliate’s possession and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.
Other Disclosures
Regardless of any choices you make regarding your Personal Information, we may disclose your Personal Information (i) to respond to subpoenas, warrants, court orders, lawful requests or legal process, (ii) to establish or exercise our legal rights or defend against legal claims or protect other users, (iii) in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or as otherwise required by law, or (iv) to investigate, prevent, or take action regarding any violation of this Privacy Policy or the TOS.
YOUR CHOICES
Changes and Deletion of your Data
If your Personal Information changes, or if you no longer desire to use or access the Ponddy Services, you may correct, update, amend, delete or request deletion by making the change in your registered account settings page, or by contacting us at support(at)ponddy-edu(dot)com. We will retain your Personal Information for as long as your account is active or as needed to provide you services. Please note that even if you have asked us to delete your account or any associated Personal Information, we may be required to keep certain information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Opting Out
We will periodically send you free newsletters and e-mails that directly promote the use of our Ponddy Services or to tell you about services we believe will be of interest to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails and you will have the opportunity to “opt-out” by following the unsubscribe instructions included in these emails or you can contact us at support(at)ponddy-edu(dot)com.
Services-Related Communications
While you may “opt-out” of certain services-related communications by following the unsubscribe instructions provided in the e-mail you receive or by contacting us at support(at)ponddy-edu(dot)com, you may not, despite your indicated e-mail preferences, “opt-out” of other services-related communications regarding your account or any payments made, or to be collected, by you, including receiving notices of any updates to our TOS or this Privacy Policy, except by terminating your account.
SECURITY
Ponddy employs technical and administrative controls and maintains the security of information collected through the Ponddy Services. Although we follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive, no method of transmission over the Internet, or method of electronic storage, is 100% secure and no company, including Ponddy, can completely or effectively eliminate the risks connected to handling information on the Internet. You acknowledge and agree that you provide your Personal Information at your own risk. If you have any questions regarding our security measures please contact support(at)ponddy-edu(dot)com.
CHILDREN
By accessing or using the Ponddy Services you affirm that you are thirteen (13) years of age or older. If you are not of legal age to accept this Privacy Policy in your jurisdiction, you affirm that your legal guardian is agreeing to this Privacy Policy on your behalf, and you must provide your legal guardian’s contact information (including but not limited to email and phone number) when creating a user account. You or your legal guardian must accept this Privacy Policy to create a user account for the Ponddy Services. If you do not have a user account, you or your legal guardian (as applicable) accepts this Privacy Policy by visiting any Ponddy Website. IF YOU, OR YOUR LEGAL GUARDIAN (AS APPLICABLE), DO NOT AGREE TO ALL OF THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, OR IF YOU OR YOUR LEGAL GUARDIAN DOES NOT HAVE AUTHORITY OR MEET THE ELIGIBILITY REQUIREMENTS AS SET FORTH ABOVE, DO NOT CLICK “I ACCEPT,” DO NOT CREATE A USER ACCOUNT, AND DO NOT USE THE PONDDY SERVICES. THE PONDDY SERVICES ARE NOT DIRECTED AT USERS UNDER THIRTEEN YEARS OF AGE. If for any reason, we, in our sole discretion, believe you do not meet the eligibility requirements set forth above, we reserve the right, with or without provision of any notice to you, to terminate your user account and this Privacy Policy. If you do not meet these eligibility requirements, we have no obligations to you under the Privacy Policy. If you are a competitor of Ponddy you may not access or use the Ponddy Services without Ponddy’s prior written consent.
CONSENT TO RECORD THE COURSE
We record each and every Session of the Course provided by our Ponddy Tutors Services, including the videos and voices of the Student and Teacher. The purpose of recording each Course is 1. to allow the parent to review the study situation of the Student, 2. to allow the Student to review the lesson for further and better learning, and 3. to allow us to manage the performance of Instructors and teaching quality. The recorded videos will be kept strictly confidential and will be for our internal use only. We will not disclose the recorded videos to the public or share the recorded videos with any third parties without the parents’ express consent. For any Student under the age of thirteen, we will send a copy of our Privacy Policy to the email address the parent submitted on our website, after the parent conscientiously read and agreed to our Privacy Policy and TOS, and make a purchase of any Course

For the above reasons, recording the session is essential for the learning and teaching quality of the course, however, if the parent still would like to revoke a prior consent to our current recording practice at any time, please email us at support@ponddy-edu.com.

HOW WE RESPOND TO DO NOT TRACK
Ponddy does not collect Personal Information about visitor’s browsing activities across third-party websites or online services. Therefore, the Ponddy Reader Website does not respond to Do Not Track Signals.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be amended by us from time to time. If we make material changes to this Privacy Policy, we will notify you by posting the revised Privacy Policy on our Ponddy Services or notifying you at the email you designated upon registration of your account. Your continued use of the Ponddy Services after such notification of changes as described above will constitute your agreement to such changes. If you object to any change, your sole recourse shall be to immediately terminate your account and cease using the Ponddy Services.

QUESTIONS AND ADDITIONAL INFORMATION
If you have any questions about Ponddy’s Privacy Policy or the information practices of this Ponddy Services, please feel free to contact us at support(at)ponddy-edu(dot)com.

Ponddy Education, Inc.
1550 The Alameda #310
San Jose, California 95126