Gakko, Inc. (“Gakko”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data we collect regarding users of our Platform. Any capitalized terms not defined herein are defined in our Terms of Service located at http://www.gakkoproject.com/terms.
1. User Consent. By using the Gakko Platform or submitting Personal Data through our online application portal, you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy and to the transfer of your Personal Data to the United States.
2. Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below. We collect information from you in a variety of ways: when you interact with our Platform and when you apply to a Gakko program.
a. Registration and Applications. We may collect Personal Data from you, such as, but not limited to, your first and last name, e-mail address, phone number, address, school information, password, and your guardian’s information when you create an account to log in to the Services (“Account”) or fill out an application (“Application”). We may also collect your device information through the Mobile Applications.
b. General – Voluntary Disclosures by You.
□ Contact Us. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
□ Other Collections. We may also collect Personal Data at other points through the Platform that state that Personal Data is being collected.
c. General – Automatic Data Collection.
□ IP Address. To make our Platform more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We may associate your IP address with your account and your Personal Data.
□ Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Platform, track users’ movements around the Platform, gather demographic information about our user base as a whole, and better tailor our Platform to our users’ needs. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
□ Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Platform. This type of information is collected to make the Platform more useful to you and to tailor the experience with us to meet your special interests and needs.
3. Use of Your Personal Data.
a. General Use. In general, Personal Data we collect is used to provide the Platform to you, enable your use of the Services, and process your Application, respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
□ facilitate the creation of and to secure your Account or Application;
□ process your Application;
□ identify you as a user in our system;
□ provide improved administration of our Platform;
□ provide the Services you request;
□ improve the quality of experience when you interact with our Platform;
□ send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
□ send you or your guardian administrative e-mail notifications, such as security or support and maintenance advisories;
□ respond to your inquiries related to Gakko programs or other requests;
□ make telephone calls to you or your guardian, from time to time, as a part of fraud protection or to solicit your or your guardian’s feedback;
□ send newsletters, surveys, offers, and other promotional materials related to our Platform and for other marketing purposes of Gakko;
□ send mobile application notifications to you; and
□ display promotions to you, including promotions relevant to your location.
□ Provide and administer any Gakko Programs that you sign up for.
b. User Testimonials. If you send us a testimonial about our Platform or any Gakko programs, we may use and disclose it (including your first name) in our discretion. However, we will obtain your consent prior to posting your full name along with the testimonial.
c. Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze usage patterns so that we may enhance our Platform and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
4. Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
a. Third Party Service Providers. We may share your Personal Data with third party service providers, for example: to any third party application processor in connection with the processing of your Application; to conduct quality assurance testing; to facilitate creation of accounts; and to provide technical support.
b. Affiliates. We may share some or all of your Personal Data with our subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
c. Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our shares, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
d. Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Gakko may disclose Personal Data (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Gakko; (c) to protect or defend the rights or property of Gakko or users of the Platform; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.
5. Your Choices Regarding Information. You have several choices regarding the use of information on our Platform:
a. Email Communications. We may periodically send you free newsletters and e-mails that directly promote Gakko and Gakko Services or programs. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Service or Privacy Policy.
b. App Notifications. We may send you notifications on your mobile device. You may disable these notifications in the settings of your device.
c. Cookies.If you decide at any time that you no longer wish to accept Cookies from our Platform for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Platform or all functionality of the Platform. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.
d. Changing or Deleting Your Personal Data. You may change any of your contact information in your Account or Application by editing your profile within your Account or Application or by sending an e-mail to us at the e-mail address set forth below. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such 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 may also retain your information for fraud or similar purposes.
e. Mobile Apps. You can stop all collection of information by the Mobile App by uninstalling it. You may use the standard uninstall processes as may be available as part of your mobile device.
6. Security of Your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account or Application information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Gakko uses reasonable efforts to protect your Personal Data, Gakko cannot guarantee its absolute security.
7. Regarding Children. Some of our Services, specifically, certain Mobile Applications, may be directed to children under the age of 13, but we do not knowingly collect Personal Data from children under 13. If we learn we have collected Personal Data directly from a child under 13 without verification of parental consent, we will delete that information. We will not use any data collected from children under 13 for marketing purposes or disclose such data to any third party except to the extent required by law or our legal obligations.
8. Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Platform. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Platform. These changes will be effective immediately for new users of our Platform Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Platform, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
9. Questions; Contacting Gakko; Reporting Violations. If you have any questions or concerns about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or email:
Gakko, Inc.
243 Canal Street, New York, NY 10013
support@gakkoproject.com
Last updated: March 30, 2018