STUDY AND WONDER LTD
PRIVACY POLICY
This privacy policy (“Privacy Policy”) governs how Study and Wonder Ltd, doing business as (dba) Brilliant Grades, (hereinafter referred to as “Brilliant Grades”, “we”, “our” or “us”) collects, uses and shares personal information:
- about each Tutee (as defined under Brilliant Grades’ Terms of Service), Tutor (as defined under Brilliant Grades’ Terms of Service), parent, legal guardian, user or visitor (collectively “you” or “your”); and/or
- you provide to Brilliant Grades when (i) accessing Brilliant Grades’ website located at https://www.brilliantgrades.com (hereinafter referred to as “Website”), and/or (ii) using the Services (as defined under Section 2.1 of Brilliant Grades’ Terms of Service).
Brilliant Grades is committed to maintaining robust privacy protections for its users. Our Privacy Policy is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using the Services on the Website.
By accessing the Website and using the Services, you accept the terms and conditions of Brilliant Grades’ Privacy Policy, and you consent to Brilliant Grades’ collection, storage, use and disclosure of your Personal Information (defined below) as described in this Privacy Policy.
You acknowledge that it is in your best interest to read this Privacy Policy carefully and to ensure that you understand the terms and conditions contained herein. Your acceptance of Brilliant Grades’ Privacy Policy is deemed to occur upon your first use of the Website. If you do not accept and agree with this Privacy Policy, please refrain from using and/or accessing Brilliant Grades’ Website and Services immediately.
Scope of Privacy Policy
This Privacy Policy governs your access of Brilliant Grades’ Service, regardless of how you access it, and explains what data we collect when you use the Website and/or Services, why we collect the data, how it is used, and your rights and choices. This Privacy Policy applies to personal data and other information collected by us from or about visitors to, or users of, our Website.
Personal Information that is Collected
Brilliant Grades collects the following information from you:
- personal information that could identify you, which includes your name, surname, gender, email address, location, professional background, employment history, professional picture, passport or identify document and/or student record when you register a User Account (as defined under Section 3 of Brilliant Grades’ Terms of Service) on Brilliant Grades Website;
- contact information which includes data such as billing address, email address, telephone numbers and any other data you have provided to us in order for us to be able to provide you with the Services on Website;
- financial data such as your bank account details and payment card details;
- transaction data which includes details about payments or communications to and from you; and
- technical data which includes your Internet protocol address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website,
(collectively “Personal Information”).
In the context of the law and this notice, the term “process” and “processing” means collect, store, transfer, use or otherwise act on data.
Use of your Personal Information
Except as otherwise stated in this Privacy Policy, Brilliant Grades does not sell, trade, rent or otherwise share your Personal Information for marketing purposes with third parties without your consent. Brilliant Grades shares only non-identifiable Personal Information with vendors and suppliers who are performing services for Brilliant Grades, such as the vendors and suppliers who provide Brilliant Grades with access to a user’s email address and email communications for the purposes of Brilliant Grades being able to send emails to you via the vendor and/or supplier’s server. Those vendors and suppliers use your non-identifiable Personal Information only at Brilliant Grades’ direction and in accordance with our Privacy Policy.
In general, the Personal Information you provide to Brilliant Grades is used to help us communicate with you. For example, Brilliant Grades uses your Personal Information to (i) make contact with you in response to questions you may ask Brilliant Grades, (ii) solicit feedback from you, (iii) provide technical support, and (iv) inform you about promotional and marketing offers.
Brilliant Grades may share Personal Information with Tutors and/or third parties if Brilliant Grades has a good-faith belief that access, use, preservation or disclosure of the Personal Information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce Brilliant Grades’ Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property or safety of Brilliant Grades’ users or the public as required or permitted by law.
Wherever possible, Brilliant Grades aims to obtain your explicit consent to process your Personal Information. We may continue to process your Personal Information on this basis until you withdraw your consent. You may withdraw your consent at any time by sending us an email at am@brilliantgrades.com. However, if you do so, please note that you may not be able to (i) use the Website, and (ii) make use of the Services further.
Automatic Collection of Information
When you visit the Website, Brilliant Grades’ servers automatically record information about your computer hardware and software. This information is collected automatically and is used only to identify potential cases of abuse, resolve technical issues, optimizing the performance of the Website for a better user experience, and establish statistical information regarding your use of the Website and the Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
How Personal Information is Secured
Brilliant Grades implements security measures that include encryption, firewalls, password management and secure socket layer technology, which are designed to protect your information from unauthorized access and potential security breaches.
Payment information is securely stored by Chargebee, Stripe and GoCardless and cannot be accessed by Brilliant Grades.
However, you acknowledge that no data transmission over the Internet or wireless network can be guaranteed. Therefore, while Brilliant Grades strives to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and another registered user on the Website and/or the Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite Brilliant Grades’ best efforts.
Storing Personal Information
Subscription Plan (as defined under Section 4 of Brilliant Grades’ Terms of Service) information and payment information is stored and secured respectively, on Chargebee, Stripe and GoCardless.
Your Rights regarding the General Data Protection Regulation
For the purposes of complying with the General Data Protection Regulation 2016/679 (“GDPR”), Brilliant Grades is considered as the data controller in relation to your Personal Information. We have listed below, the principal rights you have under the GDPR:
(i) the right to access - you can ask for copies of your Personal Information;
(ii) the right to rectification - you can ask us to rectify inaccurate Personal Information and to complete incomplete Personal Information;
(iii) the right to erasure - you can ask us to erase your Personal Information from our systems;
(iv) the right to restrict processing - you can ask use to restrict the processing of your Personal Information;
(v) the right to object to processing - you can object to the processing of your Personal Information;
(vi) the right to data portability - you can ask us to transfer your Personal Information to another organization or to you;
(vii) the right to complain to a supervisory authority - you can complain about our processing of your Personal Information to the applicable authorities; and
(viii) the right to withdraw consent – you can request that we withdraw your consent to store and process your Personal Information except to the extent that the basis of our processing your Personal Information is required by law.
You may exercise any of your rights in relation to your Personal Information by written notice to Brilliant Grades, using the contact details set out below. Should you have any cause for complaint about our use of your Personal Information, please contact Brilliant Grades using the details provided below and we will endeavour to solve the problem for you.
Analytical Data from Third Parties
Brilliant Grades may collect or receive information that third party service providers may provide about you when using the Website and/or the Services. Or Brilliant Grades may obtain information from other sources and combine that with information Brilliant Grades collects through your use of the Services. The following information is collected and/or obtained from third parties:
- Google Analytics: We use this analytical tool to help Brilliant Grades analyze (i) how users use the Website and/or the Services by noting when you use the Website and the Services, and (ii) usage data and performance data. The information collected will be disclosed to or collected directly by the applicable analytical tool Brilliant Grades is using. Such information is collected as a means to provide, improve, and develop the Website and the Services so as to create a safer and trusted environment when you use the Website and the Services.
- Chargebee, Stripe and GoCardless: We use these tools as a payment gateway provider. Chargebee, Stripe and GoCardless may collect information you provide to us as a means of processing payments you make on the Website for the Services.
- Facebook Pixels. We use this analytical tool to retarget ads and to measure the effectiveness of our advertising campaigns by understanding your interests so that we may use this information to improve and develop our Website and the Services.
Cookies
Cookies are defined as small text files that are placed on your computer's hard drive by your web browser when you visit any website. Cookies allow data gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Brilliant Grades may from time to time use cookies. They are placed by software operated by third parties whose services Brilliant Grades makes use of so as to enhance your experience on the Website.
When you first visit the Website, you may need to confirm whether you wish for cookies to be used by Brilliant Grades. If you choose not to accept them, Brilliant Grades shall not use them for your visit except to record that you have not consented to their use for any other purpose. However, please note that should you choose not to use cookies or you prevent their use through your browser settings, you might not be able to use all the functionalities available on the Website.
Brilliant Grades may use cookies for the following purposes:
(i) Authentication and status - Brilliant Grades uses cookies to identify you when you visit the Website, and as you navigate through the pages of the Website;
(ii) Personalisation - Brilliant Grades uses cookies to store information about your preferences as you navigate through the Website;
(iii) Security - Brilliant Grades uses cookies as an element of the security measures used to protect the Website and Services; and
(iv) Analysis - Brilliant Grades uses cookies to analyse the use and performance of the Website and Services.
Retention Period for Personal Information
Except as otherwise mentioned in this Privacy Policy, Brilliant Grades shall endeavour to keep your Personal Information only for a period of twelve (12) months or as long as is required (i) for Brilliant Grades to be able to provide you with Services, (ii) to comply with the law, including for the period demanded by our tax authorities, and (iii) to support a claim or defence in court.
Opt-out rights
You can stop all collection of Personal Information by Brilliant Grades by not accessing the Website and the Services, or by requesting to opt-out via email, at am@brilliantgrades.com.
Our Policy Toward Children
Our Services are directed to persons under the age of eighteen (18) years. We collect Personal Information from children under the age of eighteen (18) years. We therefore encourage you to obtain the assistance and consent of a parent/legal guardian when accessing our Website and using the Services. A parent/legal guardian who becomes aware that his or her child has provided us with Personal Information without their consent, should contact us at am@brilliantgrades.com and we will endeavour to delete it.
Changes and Amendments to Privacy Policy
Brilliant Grades may update this Privacy Policy from time to time in Brilliant Grades’ sole discretion and will notify you of any material changes to the way in which Brilliant Grades treats Personal Information. When changes are made, Brilliant Grades will revise the updated date at the bottom of this page. Brilliant Grades may also provide notice to you in other ways in Brilliant Grades’ sole discretion, such as through the contact information you have provided. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Privacy Policy will constitute your consent to those changes. However, Brilliant Grades will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Contact Information
Should you have any questions or concerns regarding privacy while using the Website and Services, please send us a detailed message to am@brilliantgrades.com, and Brilliant Grades will use its best endeavours to resolve your concerns.
Effective Date: July 21, 2020