Privacy Policy

sofatutor GmbH (“sofatutor”, “we”, “us”) takes the protection of parent and child data very seriously and adheres to the legal requirements for data protection. If you have any questions about data protection at sofatutor, you can contact us at any time at dataprotection@sofatutor.com and we will be happy to help you.

Content

General Information

For the comprehensive use of sofatutor a user account is necessary. For this purpose, an email address and a password must be provided during registration and additional detailed personal information can be stored by us.

We do not permit children under the age of 13 to create user accounts and do not knowingly collect personally identifying information from children under the age of 13 without the consent and at the direction of a parent. The user account must be created by a parent. Several child profiles can be set up however in the user account, so that children may access the platforms under the parent's supervision.

By creating a child profile associated with a parent account and permitting your child to use the sofatutor Service, you expressly agree to the practices described in this Privacy Policy and you consent to the collection, use, and disclosure of your child's personal information as described herein.

Generally, we process personal data of visitors, interested parties, customers, and users (both parents and children) of our platforms (including, in particular, our learning platform at www. sofatutor.us and our mobile app) for the purpose of providing the online offers, their content and functions, the provision of contractual services, communication with users, for marketing, advertising, and market research, and for technical security measures. Depending on the type and extent of your use of the platforms,contact, contract, payment and usage data, as well as metadata regarding access to our platforms are processed.

If, in the course of our processing, we disclose data to external service providers, this will only be done if it is necessary for the fulfillment of our business purposes or where you have consented to it. Where data is disclosed for business purposes, we have special contracts in place that protect your data and guarantee that this external business does not use your data for any other purposes than providing its services to us.

We store your data for as long as you have an active business relationship with us. After termination of this business relationship, we retain the information of the contractual relationship required by commercial and tax law. Of course, we will also delete personal data at your request if we no longer need it for the fulfillment of the contract and we are not subject to any retention obligations.

Security & Encryption

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons. The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, deletion of data and response to data compromise. We already take the protection of personal data into account during the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings. The security measures include in particular the encrypted transmission of data between your browser and our server.

We also use providers such as Stripe Payments Europe, Limited (Ireland) to prevent fraud and abuse as well as combat it. This involves collecting identifying information about the devices that connect to Stripe services and using it for fraud detection.

Access Data & Hosting

Each time you access a website, your browser transmits the IP address assigned to you at that time, as well as other metadata relating to the access (e.g. browser and operating system used, date and time of access, page or file accessed). The corresponding data is stored by us due to our legitimate interest in monitoring and ensuring the functionality of our platforms, as well as the evaluation and optimization of our offers. However, a conclusion on your person is not possible for sofatutor due to a dynamic IP address.

For the operation of our online offers, we use infrastructure and platform services, computing capacity, storage space and database services, security services as well as technical maintenance services of our hosting service provider Amazon Web Services EMEA SARL (Luxembourg). In doing so, we, or our hosting provider, process contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer in order to provide our contractual service.

Cookies

Cookies are small files that can be stored on your computer by a website. These files contain information that can be retrieved by the website when you make a new request. We use cookies to make our website user-friendly and to provide certain settings and functionalities. For registered users, for example, identification information is stored in cookies so that communication with a website can take place in a protected manner. If you register with sofatutor for a test package, we store on your computer, for example, in a cookie information about the subject combination you have selected in order to show you the corresponding videos free of charge. You can prevent the storage of cookies through your browser settings. In this case, however, the use of sofatutor's services is limited.

Contract & Payment Data

When creating a subscription, we collect personal data such as your billing address, as well as payment data for contract processing.

When paying by credit card, our payment provider Stripe collects the data directly. sofatutor does not have direct access to the credit card data entered by you, but receives the credit card number shortened to the last four digits and the card verification number. The payment service provider uses the data transmitted to you on behalf of sofatutor to charge you.

When paying via Paypal or Amazon Pay, your email address and billing data will be transmitted to us after your corresponding authorization from Paypal or Amazon Pay. sofatutor does not have any access to your payment data stored at Paypal or Amazon Pay.

The transmission of payment data only takes place via encrypted connections.

Usage Data, Videos & Exercises

When you use our platforms, we store various details about your usage behavior and learning activities, e.g. which videos you watch as a logged-in user, which exercises have been completed and what learning progress has been made. This data is used, among other things, to provide you with recommendations for videos, your most recently viewed videos and exercises, and similar functionality.

sofatutor has a legitimate interest in collecting the usage data of the platform and providing the aforementioned functionalities to our users. We also remunerate many of our video producers depending on how many users have viewed the videos of the respective producer, how many videos these users have otherwise viewed and what the respective user has paid for his subscription. To do this, we need to store the videos you have watched. In addition, we need this data in order to be able to track your use of our offer to prevent misuse, for example, through the unauthorized saving of videos.

Insofar as a user account has been linked to a learning group, such activities are also displayed within the user account that were collected in the course of interaction with the content assigned by a teacher. Thus, sofatutor also processes such usage data and can consequently be assigned to the user that was or is collected in the context of the learning groups at the instigation of the teacher. This is technically necessary to enable the linking of learning group and usage account and this ensures that uniform information regarding activities is displayed both in the learning group area and in the sofatutor profile.

Communication, Support & Chat

We use various communication channels to be available for you or to get in touch with you. In particular, you can contact us by telephone, email or chat via our website. In each case, the data you provide us with as well as, if applicable, your telephone number, email address or IP address are stored by us in order to process your inquiries.

We use the Helpscout service from Help Scout PBC (USA) to process your inquiries by email and to map our FAQ page.

Our telephone system for processing customer inquiries is operated via the Placetel service from BroadSoft Germany GmbH (Germany).

The function of direct chat with tutors on our website is technically enabled by the Olark service of Habla Inc (USA). In this context, the data of logged-in users is forwarded by Olark to our staff (internal and external).

In addition, we offer a personal introduction to our website. For this purpose, you can make an appointment by providing the necessary information such as name, email address, telephone number, choice of learning subjects and grade level of your child. One of our guides will then contact you by phone and conduct the tour together with you. We make this call with the help of the provider Aircall SAS (France). Only if you give us your explicit consent, your call will be recorded for training purposes only and will be deleted after one year.

sofatutor can also assign freelancers to take care of the chats. For this purpose, general data of the user transmitted by the browser, such as the browser used, and for logged-in customers, further customer data (user name, email address and the subject/topic of the current video) are transmitted in order to be able to help you as well and quickly as possible.

Customer Surveys & Ratings

sofatutor uses the services SurveyMonkey (USA) and Hotjar (Malta) to survey customers through a pop-up after the purchase process. In doing so, your browser communicates directly with the services. As a matter of principle, sofatutor does not transmit any further data and receives a statistical evaluation of the answers without personal reference. A user ID is transmitted to SurveyMonkey or Hotjar, but neither SurveyMonkey nor Hotjar can use it to identify you.

sofatutor has a great interest in documenting the satisfaction of our customers through independent surveys and to use this information for further improvements. Therefore, on our behalf, the service eKomi of eKomi Holding GmbH (Germany) determines the satisfaction of our customers through surveys by email.

Email Communication and Advertising

We use the email address provided by you when creating a user account or when concluding a sofatutor subscription in order to contact you regarding our respective contractual relationship and to be able to send you all important and further information that is of interest to you on the one hand.

On the other hand, we use your email address to inform you about products and other sofatutor offers in which you have a presumed information interest. This also applies to the advertising of our paid offer if you have initially only selected access to our free offer by creating a user account. You can object to the use at any time by sending a message to the email address below or by clicking on the unsubscribe link in the email without giving any reasons.

sofatutor uses the providers Episerver GmbH (Germany) and SendGrid of Twilio Inc. (USA) for sending offers and information by email. In this regard, email addresses, names, and other information regarding your interaction with our emails are stored on servers of these providers. However, personal data may not be used by these providers for purposes other than sending emails on behalf of sofatutor.

Under certain circumstances, we may also use your contact data that we have collected in the course of entering into a contractual relationship with you in order to be able to inform you by mail about offers, for example, if the term of your subscription is coming to an end or has already expired, or if you have cancelled or revoked your subscription within the free trial period.

In addition, we conduct general analyses of existing customers in order to obtain a better picture of our customer base and, if necessary, to potentially approach new, similar customers based on this. For this purpose, we sometimes use external providers, with each of whom special contracts are concluded for the protection of your data.

You can object to the use of your personal data for the aforementioned marketing purposes at any time free of charge with effect for the future by sending an email to dataprotection@sofatutor.com.

Web Analysis & A/B Testing

sofatutor uses various web analytics services to review and improve its offering. These are partly integrated via the Google Tag Manager, which enables the administration of the services. The Tag Manager itself does not set any cookies and does not collect any personal data - except for the IP address, which is technically necessary for the execution of the Tag Manager. The services collect information about your usage behavior, the browser you use and settings. This information can neither be linked to your person by the web analytics services nor by sofatutor.

In detail, these are the following services:

Google Analytics - sofatutor uses Google Analytics, a service of Google Ireland Ltd (Ireland), to analyze and improve the offer. Google Analytics uses cookies, text files that are stored on your computer and enable an analysis of your use of sofatutor. The information generated by the cookie about the use of sofatutor is transferred to a Google server in the USA and stored there. sofatutor uses IP anonymization for Google Analytics. Your IP address is therefore shortened by Google before transmission in a member state of the European Union or a contracting state of the Agreement on the European Economic Area, so that a personal reference can no longer be established, even by third parties. We can also use the data collected by Google Analytics to place particularly relevant advertisements on other websites for certain user groups (e.g. visitors to a certain page of the platforms) via Google AdWords. It is not possible for us to identify individual persons in this process. You can revoke your consent to the collection and storage of data at any time with effect for the future by downloading and installing the browser plugin available under the following link
https://tools.google.com/dlpage/gaoptout?hl=en.
Amplitude - In order to make the functions of sofatutor even more user-friendly, we use the analysis platform of the company Amplitude Inc (USA). The service helps us to learn, for example, how our users get to an exercise task and thus to optimize this path. As is usual with external resources, your IP address and your User ID are transmitted to the third-party provider. The User ID does not contain any personal data.
Convert - For testing improvements on the platforms, sofatutor uses the convert service of Convert Insights Inc. (USA) (A/B tests). This involves randomly selecting a portion of our customers to display possible changes in order to test their popularity. A request is sent from your IP address to Convert in order to statistically record the behavior on the website.
Hotjar - sofatutor uses Hotjar, a service provided by Hotjar Ltd (Malta), to analyze and improve its services. Hotjar uses cookies, which are text files placed on your computer, to help the website analyze how users use sofatutor. The information generated by the cookie about the use of sofatutor is transmitted to a server in Ireland and stored there. Your IP address is shortened by Hotjar before transmission and thus anonymized, so that a reference to a person can no longer be established, even by third parties. The complete privacy policy of Hotjar can be found here. If you do not wish your data to be collected by Hotjar, you can object to this here.
Unbounce - In order to inform interested parties as well and helpfully as possible and to constantly improve the offer, sofatutor uses the service Unbounce of Unbounce Marketing Solutions Inc. (Canada). For promotions or advertising campaigns, individual pages are hosted by Unbounce and sofatutor receives an evaluation of the activities of the interested parties. Your browser communicates directly with Unbounce so that your IP address is transmitted and cookies can be set.
Scout - To check the functions of us.sofatutor.com, the service Scout of Zimuth Inc. (USA) is used. Data about the execution of the program code is collected in order to analyze in particular the loading times of individual page components. The evaluation of this data is transmitted to sofatutor in aggregate form and it is not possible for sofatutor to establish a relationship to individual users. Only for calls where problems such as a particularly slow loading time occur, information about individual calls is also transmitted. An identification of the user is not possible for sofatutor even in this case, only if you were logged in on our site. No further user data is transmitted by sofatutor to Scout.
Bugsnag - In order to correct errors and problems with the functionality of us.sofatutor.com, sofatutor uses the service Bugsnag of Bugsnag Inc (USA). In the event of an error, the IP address, data on the user's settings (e.g. the browser used) and details of the page where the error occurred and the data entered are transmitted to Bugsnag for evaluation, categorization and analysis of the error.
Sentry - In order to check our code for errors and thus to be able to ensure the technical stability of our offer, we use the Sentry service of Functional Software, Inc (USA). For this purpose, information about your browser, terminal device and operating system as well as user ID is processed. You can find more information about this in Sentry's privacy policy here.
Userlane - We use the service of Userlane GmbH (Germany) for the display of statements as part of the personal introduction on our website. Cookies are set for this purpose. Further information here.

Marketing & Advertising Provider

We use various external service providers and advertising networks to market our offer. The following applies to all tools: You can object to their use by making the appropriate setting in the cookie preferences.

Cookie-Preferences

Advertising providers (Google Ads (USA), Bing Ads (USA), Facebook Ads (USA), Taboola (USA), Outbrain (USA), Doubleclick (USA), YouTube (USA), Pinterest (Ireland), TikTok Ads (Ireland and the UK), Podsights (USA)) are integrated when using the platforms without being logged in as a registered user. Thus, when you access the platforms, a request is sent to these third-party providers. Your browser then communicates directly with the respective third-party provider. The provider learns your IP address and can store cookies on your computer. These cookies only contain the information that you are interested in our platform, so that advertising for sofatutor, such as special offers, can be delivered to you on websites of the partners of these advertising providers. sofatutor itself does not access cookies of third-party providers and does not transmit any personal data to these advertising providers.

Also, after logging in to sofatutor, a request is sent to our advertising partners. Your browser then communicates directly with our partners. This allows them to check whether a corresponding cookie is stored on your computer due to previous interaction with advertising of the respective partner and then inform us about the number of registrations/purchases.

The privacy policies, as well as the configuration of the interest-based advertising of the advertising providers can be viewed at the following links:

Facebook Conversion API: We use the Facebook Conversion API, a server-side event tracking tool, on our website. It is a data interface through which we transmit data about your behavior on our website to Facebook for evaluation and thus display ads to you that match your user behavior on our website. Usage data (e.g. web pages visited, interest in content, access times) as well as meta/communication data (e.g. device information, IP addresses) are processed. Your data will not be passed on to third parties. However, we work together with Facebook to create user statistics. In the process, data may also be processed in the USA. As a basis for this data processing, we use the standard contractual clauses approved by the EU Commission. Provider: Meta Platforms Ireland, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Information on data protection can be found here.

Information in Connection with the Use by Teachers and Schools

If you are interested in using sofatutor for your school, you can contact us by providing your name, email address, and other information necessary to create an offer. Depending on the license you purchased, your teachers and possibly students will then receive access to the platforms. Your teachers and students must register with us by providing an email address and a password so that we can ensure that only authorized users have access to our content. If your students are minors less than 13 years of age, you must ensure that the respective accounts are created by the parents, who must consent to the processing of their children's personal information according to this privacy policy.

Criminal Behavior of Users

The data required for criminal prosecution will be forwarded to law enforcement agencies if there is a reasonable suspicion of a criminal offense, such as fraudulent disclosure of the account details of a third person.

User Rights

Access and deletion of your child’s personal information

By signing in to the user account, the parent can review the information collected from the user of the child profile at any time. The parent may refuse to permit the further collection of the child’s information by no longer providing the child access to our platforms. To request deletion of personal information of a child, please submit a request via email to dataprotection@sofatutor.com.

California Residents

If you are a resident of the state of California, you have certain rights with respect to personal information that we have collected about you under the CCPA. Exercising these rights is not associated with any disadvantages to you.

Right of Access / Deletion

You have the right to know more about the personal information we have collected about you in the last 12 months. Also, you have the right to request the deletion of your personal information, subject to certain exceptions. In order to exercise these rights, please submit a request via email to dataprotection@sofatutor.com

Right to Opt Out / Do Not Sell My Personal Information

Furthermore, you have the right to direct us not to sell your personal information. Please note that we will never “sell” personal information to third parties without your consent. However, we allow the third parties set out above to collect personal information through cookies or similar technologies, e.g. for marketing purposes. Please see the sections "Web Analysis & A/B Testing" and “Marketing & Advertising Providers” for more information about how third parties use cookies and related technologies to collect information. In case of users that are less than 16 years of age, this only takes place where we received the prior consent from either the minor who is between 13 and 16 years of age or the parent of a minor less than 13 years of age. In any case you can Opt Out from the use of cookies and similar technologies and the resulting “sale” of your personal information by adjusting the settings in our cookie consent accordingly.

Cookie-Preferences

Nevada Residents

You have the right to direct us not to sell your personal information. You can Opt Out from the use of cookies and similar technologies and the resulting “sale” of your personal information by adjusting the settings in our cookie consent accordingly.

Cookie-Preferences

Changes to this Privacy Policy

In the event of a change in legal regulations or our service, it may become necessary to adapt this data protection statement. If material changes to this Privacy Policy are made, we will notify you by posting a notice on our website or through other appropriate communication channels. The current version of the data protection provisions can be viewed at any time at www.us.sofatutor.com under the link https://us.sofatutor.com/legal/privacy-policy.