Privacy Policy
Last Modified December 6, 2022
Our privacy commitment
This Privacy Policy describes the way in which Online Reading Tutor Services Inc. referred to in this Privacy Policy as “Online Reading Tutor,” the “Company,” “we,” or “us”, or words of similar meaning) collects, uses, discloses, and safeguards personal information provided to us by Learners, Parent/Guardians, teachers and others (collectively “Users” or “you”) when they train on our website or mobile applications (collectively, together with any other services that Online Reading Tutor may from time to time provide at onlinereadingtutor.com or at any other Online Reading Tutor website that links to our Terms of Use, the “Services”).
Our Users are required to accept this Privacy Policy when they accept our Terms of Use. Capitalized terms used and not defined in this Privacy Policy have the meanings given to them in the Terms of Use.
In support of Online Reading Tutor’s Education’s mission to help every learner in the world learn to read and read to learn, we are committed to protecting the privacy of our Users and providing a safe, online learning environment. Online Reading Tutor is committed to only collecting from Learner Users of Online Reading Tutor’s training materials, such as Online Reading Tutor Math and Online Reading Tutor English (we refer to these as “Training” or “Trainings”), the information needed to individualize the Learner’s learning, enable progress monitoring for Parent/Guardians and teachers, and optimize the Training experience.
Online Reading Tutor does not permit third-party advertising in our training, and Online Reading Tutor does not sell, lease, or otherwise trade for value any personal information of learners. Learners’ information is only used to provide and improve our services.
Types of User information we collect
How we use User information
How we share User information
How we protect User information
Users’ rights regarding their information
iKeepSafe and Online Reading Tutor’s work on children’s information privacy
Storage and retention of User information
Updates to this policy
How to contact us
1. Types of User information we collect
We and our service providers collect information when Users visit our website or create an account to use the Services. The types of information we collect vary depending on the type of User who engages the Services, including:
“Parent/Guardian Users” (also called “Parent/Guardians”), which means parents or guardians of Learner Users.
“Learner Users” (also called “Learners”), which means a child or other learner who uses the Services.
A Learner User account can be linked to one or more Parent/Guardian Users (in this Privacy Policy we refer to a linked Learner User account as “your Learner” in relation to the applicable Parent/Guardian Users) in order to facilitate a continuous learning journey for that Learner User both in and outside of the classroom. Any Parent/Guardian Users linked to that Learner User account will have access to the information in that account, including activity recorded both in and outside of the classroom.
More information on each type of account can be found in our Terms of Use.
Information Collected From Users
We collect information from Users when they send it to us. For example, when you sign up and purchase a product or service, sign up to receive our newsletter, or otherwise contact us with a customer support question, chat, comment, or request, we may collect the information you provide.
If you submit any information relating to other people in connection with your use of the Services, you represent that you have the authority to do so and you permit Online Reading Tutor to use and share that information in accordance with this Privacy Policy.
Learner Users
We collect information about Learner Users when the Learner creates an account directly with us or when the Learner User account is created by a Parent or Guardian. We are committed to collecting the minimum amount of information about Learners needed for us to operate the Services effectively.
When an Online Reading Tutor Learner User account is created, we collect the Learner’s:
First name
Grade
Learners are assigned a unique username based on their first name which is used to log in but is not visible to other Users except for that Learner’s linked Parent/Guardians. The Learner then selects a fictional avatar name and appearance from a list of options, which are the only ways that users are differentiated within the Service, although these avatar names and appearances are not unique (i.e., there can be multiple Users who choose the same avatar).
Parent/Guardian Users
When registering with Online Reading Tutor, Parent/Guardian Users are asked to provide personal information, including but not limited to their first and last name, email address, password, and Location (country, state or province) for their account. Online Reading Tutor also collects Learner User - mentioned above - information regarding Learner Users associated with Parent/Guardians for purposes of linking the Learner and Parent/Guardian accounts.
For Parent/Guardian Users with a paid membership, those Users must also provide payment information. Online Reading Tutor does NOT directly collect and store that credit card information — all credit card information and purchase transaction information is instead collected and stored by our third-party payment providers, such as Stripe or the app store through which you purchased our membership.
Information Collected From Devices and Use of the Services
Performance data
As Learners train on the Online Reading Tutor apps or use other Online Reading Tutor Services, we collect information on the features they interact with, reading skills they encounter, and questions answered (“Performance Data”). This information could include, but is not limited to, data on which activities a Learner completes, the number of questions answered correctly or incorrectly, where the Learner is in the curriculum, and time taken to answer questions. As described further in the next section, we use Performance Data to provide the Services, including to customize a Learner’s educational experience. Where a Parent/Guardian and/or a Guardian is linked to a Learner, the Learner’s Performance Data is reported to that Parent/Guardian to allow for monitoring of the Learner’s progress and to customize the Learner’s educational experience.
Device data and information collected by technology (e.g., cookies)
Like most websites and online services, Online Reading Tutor and our third-party providers automatically collect certain technical information from your computer or mobile device over time and across different websites when you use the Services, such as your IP address, your browser type, your operating system, the pages you view on the Services, the pages you view immediately before and after you access the Services, and other information about your use of the Services. All of this information may be collected through use of “cookies,” which are small text files that the Services save on your computer using your web browser and access when you return, and other similar technologies, like “pixel tags,” which are pieces of code placed on a web page that can collect information about whether a User has been to a certain web page or clicked on a specific advertisement.
The information collected through these technologies includes information about the way you arrive at and use our website, products and services, including the pages you visit, the links you click, how frequently you access the product, or whether you open emails or click links contained in the emails we send you. It also includes information about high-level geographic location, such as a User’s state or region as approximated by the User’s IP address, for reasons such as associating a User with the appropriate curriculum, product improvement, and sending locally relevant marketing communications to Parent/Guardian Users. We and our third-party providers also collect analytics data, for example through the use of tools such as Google Analytics, to measure traffic and usage trends for the website and to understand more about the demographics and behaviors of our Users. We also use third-party advertising providers to collect information about Parent/Guardian Users who visit areas of the Services that are not directed to Learner Users. This includes information used to deliver interest-based advertising to Parent/Guardian Users, including advertising for our Services, when those Users visit third-party websites, and provide us with statistics about the effectiveness of our advertising on third-party websites.
We and our third-party providers may use the information collected through these technologies for the purposes described in this Privacy Policy, including delivering content, analyzing our Users’ experience on the Services, and delivering advertising to Parent/Guardians when they visit other websites and applications. Cookies and these other technologies placed within the Online Reading Tutor Training or within other areas of the Services directed to Learners will be used only in support of the Service’s internal operations, like providing access to the Trainings and their features, individualizing content, and improving and optimizing the Services. We do not allow third-party targeted advertising providers to collect information from the Learner-directed portions of the Services.
Information from Third Parties
We may obtain information about you or your use of the Services from third parties and sources, such as our vendors, like single sign-on providers you can use to log into the Services, web hosting providers, analytics providers, or advertisers. In certain circumstances, you may give us permission to access your information from some of these services offered by third parties. The information we obtain from third-party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies. You are responsible for reviewing the privacy policies of these third parties and adjusting your settings to meet your preferences. When you access the Services through third-party platforms, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy.
2. How we use User information
How we use Parent/Guardian User information
We use the Parent/Guardian information we collect for the following purposes:
To allow Parent/Guardians to register for and use the Services, such as when you securely log into your portal, to send a communication about a Learner’s progress or account, or provide feedback to us. For confidentiality purposes, information about a Learner is only provided to a Parent/Guardian linked to that Learner’s account.
To analyze and provide progress reports to Parent/Guardians on linked Learner User accounts.
To process payments. NOTE: Online Reading Tutor does NOT directly collect or store credit card information — such information is collected and stored by our third-party payment providers, such as Stripe or the app store through which you purchased our membership.
To communicate with Parent/Guardians regarding your account, including providing information about changes to the Terms of Use, updates regarding our services, security alerts, communication about your linked Learner’s progress or account, or responses to customer support questions.
To send marketing communications of potential interest to Parent/Guardians. You can choose to stop receiving marketing emails from us by following the instructions contained in these emails.
To deliver, tailor, and measure the effectiveness of advertising to Parent/Guardian Users. For example, when Parent/Guardians visit third-party websites and applications, our third-party providers may deliver Online Reading Tutor ads based on visits to areas of the Services that are not directed to Learners.
How we use Learner User information
We use the Learner User information we collect for the following purposes:
To measure a Learner’s progress and performance and provide associated reports to Parent/Guardian Users.
To adapt, personalize, and customize the Learner User experience to the Learner’s learning needs.
How we use all User information
We use all User information we collect for the following purposes:
To monitor, maintain, analyze and improve the functionality of the Services.
To assess and improve the products and services and its educational content, and to improve the user experience.
As we believe to be necessary and appropriate to detect violations of and enforce our Terms of Use; to protect the security of the website, products and services; to protect the rights, privacy, property, or safety of Online Reading Tutor, you, or others; and to allow us to pursue any available remedies or to limit damages that we may sustain.
De-Identified or Aggregated Information
From the information collected through the Services, Online Reading Tutor may create de-identified or aggregated data. What this means is we remove certain identifiers and delineative features of the data collected that make it personally identifiable to a particular User so that it no longer allows a User to be directly or indirectly identified. We may use or disclose such de-identified or aggregated data for lawful and legitimate business purposes, including to analyze, build and improve the Services and promote our business. When we share such information, it will not be shared in a way that could be used to identify a User.
3. How we share User information
We only share information collected in limited circumstances. We do not disclose the personal information of Learners to third parties for marketing or promotional purposes.
We share User information with third parties as follows:
Where a Learner User account is linked to a Parent/Guardian, that Learner User’s information will be shared with the Parent/Guardian.
To third parties that perform certain services for us such as analytics, credit card processing, or research or evaluation of the Services, provided those service providers agree to safeguard the information, keep it confidential, and use it only for the purposes permitted by our agreements.
To inform or support the consideration, negotiation, or completion of a possible merger, sale, financing or transfer of all or a portion of our business to another entity. If some or all our assets are acquired or otherwise transferred or licensed, including in bankruptcy, Online Reading Tutor shall take reasonable steps to subject such acquirer to the same commitments stated under this Privacy Policy.
Where you have instructed us to, for example to support inquiries either at your direction or with your informed consent.
As we believe to be necessary and appropriate to detect violations of and enforce our Terms of Use; to protect the security of the website, products and services; and to allow us to pursue any available remedies or to limit damages that we may sustain.
We may disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the rights, privacy, property, or safety of Online Reading Tutor, you, or others; to address fraud, security or technical issues; or to protect our or any other person’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
In some cases, personal information that we collect may be stored or processed outside of Canada. In such cases, we continue to protect the information with appropriate safeguards, but it may be subject to the legal jurisdiction of those countries and governmental authorities in those countries.
As described above, we also use third-party advertising providers to collect information about Parent/Guardian Users who visit areas of the Services that are not directed to Learner Users to deliver, tailor, and measure the effectiveness of advertising to Parent/Guardian Users.
4. How we protect User information
The User information we collect is stored and processed in environments designed to allow only authorized individuals to access the infrastructure where this information is stored. Because we understand and respect the trust placed in us to properly protect your information, Online Reading Tutor takes great care to maintain commercially reasonable standards of data security and protection, and continues to implement those measures for our infrastructure where User information is stored.
Online Reading Tutor and its service providers maintain strict administrative, technical, and physical measures designed to safeguard the information we process. We use industry-standard SSL encryption when collecting or transferring your information. Other safeguards include but are not limited to data encryption, firewalls, multi-factor authentication for our personnel with access to your information, and physical-access controls.
You can protect against unauthorized account access by selecting and protecting passwords appropriately, including using unique, multi-character passwords, ensuring devices are only accessed by those authorized to use them, and taking care to sign out of online accounts (not just Online Reading Tutor, but all online accounts) after you or your Learner Users are finished using them. Access to information associated with User accounts is limited to those Online Reading Tutor staff members who require such access to support our Services, who are designated and trained to maintain the security and confidentiality of User information.
5. Users’ rights regarding their information
Access, correction or deletion of information
Parent/Guardian Users may contact our customer support at any time to access, correct or delete their personal information which is collected and used by Online Reading Tutor. Personal information can be accessed and changed. You also can access and review certain account-related details by logging into your online account.
Parent/Guardian Users may also contact our customer support at any time to access, correct or delete any personal information we have collected from or about Learner Users associated with their account, including a request to us to cease collecting personal information from those Learner Users. Please be aware a request to delete or cease collecting personal information may lead to closing of the relevant User’s account or the inability to use the products or Services or certain portions of the products or Services.
When a correction, deletion or other change to Learner User personal information is requested and validated, Online Reading Tutor will effect the change as soon as reasonably practicable and in accordance with privacy laws.
Advertising & your choices
As described above, in certain instances Online Reading Tutor uses third-party partners to deliver, tailor, and measure the effectiveness of interest-based advertising to visitors to the areas of our Services that are not directed to Learners. For example, when Parent/Guardian Users visit third-party websites and applications, our third-party providers may deliver Online Reading Tutor ads based on visits to areas of the Services that are not directed to Learners. To learn more about interest-based advertising and how you can opt-out or limit some online advertising and tracking, you may wish to review the following tools and options:
Network Advertising Initiative (NAI) at http://www.networkadvertising.org/choices
Digital Advertising Alliance (DAA) at www.aboutads.info/choices and http://youradchoices.com/appchoices and the mobile AppChoices app
Digital Advertising Alliance of Canada (DAAC) at https://youradchoices.ca/ and https://youradchoices.ca/en/appchoices and the mobile AppChoices app
Apple operating system (iOS) settings on your mobile device, select “limit ad tracking”
Android operating system settings on your mobile device, select “opt-out of interest-based ads”
Opting out of email communications
You can opt out of receiving commercial or promotional emails from Online Reading Tutor by following the unsubscribe instructions indicated in the email, manage your communication preferences or contacting customer service. Online Reading Tutor communication preferences can be managed through our preference center, available through a link in the footer of our commercial or promotional emails, through which users can specify which types of communications they would like to receive.
California privacy rights
California law also grants its residents certain rights regarding the collection and use of their personal information. This section does not apply to Learner personal information we process on behalf of an educational institution customer, either pursuant to contractual restrictions or through a Teacher Account, to process the information solely on behalf of the institution as an educational service provider.
Subject to certain limitations, California residents have the following rights:
Right to know. You have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information.
Right to delete. You have the right to request the deletion of your personal information, subject to certain exceptions.
Right to opt out. You have the right to opt out of any sales of your personal information. Note that while Online Reading Tutor does not monetize the personal information of any User of the Services by providing it to a third party in exchange for money (except in the context of a potential sale of the company), California law has a broader definition of the term “sell” which includes making user information available to a third party for the purposes of targeted advertising. As described above, when we work with our advertising partners, we allow them to collect information about Parent/Guardian Users and Teacher Users who visit areas of the Services that are not directed to Learner Users. These Parent/Guardian Users and Teacher Users can direct us to stop allowing the collection of their information in this way by opting out of cookies through our cookie preference center, accessible within the footer of our website at Online Reading TutorTraining.com. By contrast, Online Reading Tutor does not sell, lease or otherwise trade for value any personal information of Learner Users, including within the training.
Right to not be discriminated against. You have the right to be free from discrimination for exercising these rights. Please note that if the exercise of these rights limits our ability to process personal information we may no longer be able to provide you with our products and services.
If you are a California resident and would like to exercise any of these rights, please submit an email request to privacy@onlinereadingtutor.com with the subject line, “California Rights Request.” We may need to verify your identity before processing your request, which may require additional personal information from you, or that you log into your Online Reading Tutor account. In certain circumstances, we may decline or limit the scope of our compliance with your request, particularly where we are unable to verify your identity or locate your information, or as permitted by law.
If you are submitting a request through an authorized agent, the authorized agent must provide us with your signed written permission stating that the agent is authorized to make the request on your behalf. We may also request that any authorized agents verify their identity and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf.
Users in the European Economic Area (EEA), United Kingdom, and Switzerland
If you are a resident of the EEA, UK, or Switzerland, the following information applies with respect to personal information (or personal data) collected through your use of our Services. As noted above, Online Reading Tutor processes personal information consistent with our disclosures in this Privacy Policy.
We process personal information on the following legal bases:
With your consent
As necessary to Online Reading Tutor to perform its obligations under any agreement for Services
As necessary for our legitimate business interests to provide the Services where those interests do not override your fundamental rights and freedoms related to data privacy.
Note, the information we collect may be transferred, stored, and processed in Canada and the United States or any other country where we or our processors maintain offices. We will work to make transfers of personal information to a third country or an international organization subject to appropriate safeguards under applicable law.
You are entitled to the rights under Chapter III of the EU General Data Protection Regulation and the UK GDPR, or Section 2 of the Swiss Federal Act on Data Protection concerning the processing of your information, which includes rights to access, correct, delete, restrict or object to our use of, or receive a portable copy of your personal information. You also have a right to lodge a complaint with your local data protection regulator. To make a request or otherwise exercise your rights, please contact us at privacy@onlinereadingtutor.com. To honor such a request, we will need to verify your identity and residency, which may require additional supporting information.
6. Storage and retention of User information
Information collected through the Services may be transferred, stored and processed in Canada and the United States or any other country where we, or affiliates, or our processors maintain offices, which may not provide the same level of protection for your personal information as your country, state, or province of residence, in which case it will be subject to and may be available to the government under the laws of that jurisdiction, including law enforcement, regulatory, and national security authorities.
We retain your personal information for as long as we have a relationship with you, although we retain the right to delete User accounts after a period of inactivity. After our relationship has ended, we also may retain your personal information for as long as required by law or to investigate or defend against potential legal claims.
7. Updates to this policy
This Privacy Policy may change from time to time. To the fullest extent permitted by applicable law, Online Reading Tutor may amend this Privacy Policy, in whole or in part. If we do amend this Privacy Policy, we will notify Users at least thirty (30) days before the amendment comes into effect. Such notice will be provided by posting the new version of this Privacy Policy on our website and updating its “Last modified date” set out at the top of this Privacy Policy. If any such amendment materially increases a User’s obligations under this Privacy Policy or materially reduces Online Reading Tutor’s obligations to a User under this Privacy Policy, we will also at least thirty (30) days before the update comes into effect either send a notice to affected Users to the contact email address contained in their account Registration Data (as defined below), or we will display an alert on our website and our mobile applications upon their next login to the Services.
This Privacy Policy may not otherwise be amended without our express prior consent.
8. How to contact us
If you have questions or concerns regarding the way in which your personal information has been used, please contact us at privacy@onlinereadingtutor.com, or by calling us at 1-289-356-5563.