Yo!’s privacy policy

TUTOR PRIVACY NOTICE

Last updated: January 8, 2025.

INTRODUCTION

We, at YO! INGLÊS, respect the privacy and confidentiality of the personal data of our tutors and yosers in our possession. We have implemented policies and practices to safeguard the collection, use, disclosure, and storage of the personal data provided to us. This data privacy notice covers tutor-applicants and tutors.

Yo! Edtech LLC is the Data Controller of all the personal information collected and processed in the course of business of YO! INGLÊS.
We define Personal Data as any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information to directly and certainly identify an individual.
We will not collect, process, or store you personal data unless:

• We have acquired consent or contractual agreement from you.
• We have a lawful purpose directly related to our business activity and the collection, processing and storage is necessary for that purpose.
• The personal data collected, stored and processed is not excessive in relation to that purpose.

WHERE WE COLLECT AND STORE YOUR PERSONAL DATA

We collect your personal data through:

• Our company websites
• Outsourced Services
• Finance Department
• Customer Service / Tutor Support
• Social media
• Sales/Marketing Department
• Recruitment Department
• International / Overseas Collection Points

PERSONAL DATA ABOUT YOU THAT WE PROCESS

The types of personal data we collect about you and process (or have a service provider process on our behalf) may include:

• Communications and Correspondence
• Demographic Information
• Educational Qualifications
• Financial Information
• Location
• Photos & Video Footage; and
• Other information that you may divulge in the course of your sessions.

OUR PURPOSES FOR PROCESSING YOUR PERSONAL DATA

We use and otherwise process the personal data we have collected about you for one or more of the following purposes:

• Carry out our obligations arising from any contracts entered into between you and us (e.g. payment for your services, quality monitoring)
• Comply with or fulfillment of our legal obligations and regulatory requirements
• Enforcement of obligations owed to us
• Provision of services to clients
• Data analysis and research
• Management and improvement of our business and operations
• Enhancement of customer experiences
• Development of new products and services
• Processing of applications and registrations for our services
• Processing of contract renewals and upgrades
• Responding to queries and feedback, and providing customer service and account management
• Recruitment & applicant selection

YOUR RIGHTS AS DATA SUBJECTS

You have certain rights and choices with respect to your information, such as:

• Withdrawal of Consent

At any time you may withdraw your consent to collect, use, disclose, store or otherwise process your personal data. If you choose to do so, we will delete any information that we are processing based solely on your consent (and not due to a contractual agreement or other overriding legitimate business interest). If you choose to withdraw consent, you should give us reasonable advance notice.

• Restricting the Processing of Personal Data

You may also give us notice in writing at any time telling us to suspend, withdraw or delete personal information for a specified purpose or in a specified manner. This may also include removal or destruction of your personal information in our care. Do note that there will be instances where we may retain some of the information we have collected if we have your contractual agreement, legitimate business reasons, legal or regulatory obligations to do so. In such cases, we will inform you that we are doing so.
Your withdrawal of consent or request to restrict any processing activity can take the form of an email to us. Where relevant, we may need you to provide proof that the personal information is incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or are no longer necessary for the purposes for which they were collected.
We will then notify you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future updates or that the quality of our service to you may be impacted.

• Accessing and Correcting Personal Data

You may ask us (in writing) to inform you what personal data we hold and relevant details about what is being processed by us or by a service provider on our behalf for a particular purpose and, if you say that you would like to receive it, to give you a copy of that personal data in an intelligible form and in a form that is easily portable.
You need to ask us separately for such access to personal data that we hold for each different purpose. We may charge you a reasonable fee for each access request you make to us if there is a cost involved.
We will respond to your request for access to personal data about you within a reasonable time framework after we receive your request. If we are not able to do so fully within that period, we will let you know the reasons.
When you make such a request, we may need to verify your identity - for example, by checking your valid ID or other legal identification document.

• Accuracy of Your Personal Data

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading, and kept up-to-date by having regard to the purpose, including any indirectly related purpose, for which we collect the personal data and further process it.
You may ask us to correct personal data about you where the personal data is inaccurate, incomplete, misleading, or not up-to-date. Where we are satisfied that the correction should be made, we will make it within a reasonable time framework from the date we receive your request and give you a copy of the corrected personal data.
From time to time, we may do a verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us if there are any changes in the personal data we hold about you (such as a change in your personal address).

DISCLOSURE AND CROSS-BORDER TRANSFER OF PERSONAL DATA

There is no cross-border data transfer of your Personal Information to any place beyond Yo! Edtech LLC, whose computer systems are currently based in Brazil. By agreeing to this notice, you consent to the transfer of all such information to Brazil, which may not offer a level of protection equivalent to that required in the European Union, United Kingdom, or certain other countries, and to the processing of that information as described in this notice.

We ensure that we will not disclose, share, and sell your personal information collected and stored in the course of our business to 3rd parties, without your consent. Nonetheless, our obligation does not extend to any information you share with your yosers, co-tutors, and vice versa during session and private conversation. In no way do we take responsibility for any personal information shared, disclosed, or spread that is beyond the control of the company. Be cautious in sharing your personal information to yosers and co-tutors.

Your personal information is publicly shown and uploaded on www.yoingles.com and other YO! INGLÊS websites. This information includes your tutor name, photo, video, nationality, and bio, which can be seen by anyone and is accessible to the public. Any person may share, take a screenshot, or download the content. We upload your personal information on the site for profiling and marketing because the yosers choose their tutors through the website.

If there is a need for us to transfer personal data about you to a place outside Yo! Edtech LLC, we ensure that the recipient will be obliged to provide us with security measures that meet the standard of protection that we require for such transferred data. We are allowed to transfer personal data about you in various circumstances permitted by law (for example, for the purpose of a contract between you and us or in an emergency concerning you.)
In the event that the competent authorities enforce its power to collect, search, and possess your personal data, we will disclose your personal information even without court order based on the following grounds:

• The information is required for safeguarding national security; or
• Failure to provide the data would prejudice the prevention or detection of crime, the apprehension or prosecution of offenders, or the assessment or collection of any tax or duty.

Before we release your information, we will ensure that the information is being provided to a genuine and properly authorized agency. If we are not convinced and doubt the legitimacy of the agency requesting your information, we will decline the request pending the presentation of a court order. We will only release personal information in proportion to what is necessary.

PROTECTION OF PERSONAL DATA

We take practical steps to protect personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction having regard to the nature of the personal data and the harm that would result from any of such things happening. We provide security measures of the place or location where we store the personal data, or its transfer to ensure the reliability, integrity, and competence of the personnel having access to it.
Entities that provide services to us to process personal data on our behalf will be bound by contracts that require them to provide guarantees in respect of the technical and organizational security measures governing the processing to be carried out and to take reasonable steps to ensure compliance with those measures.

CLIENT INFORMATION POLICY FOR TUTORS

This policy, the Client Information Policy for Tutors (herein “the policy”), specifies the rules for how client information provided to YO! INGLÊS (herein “the service”), a service operated and provided by Yo! Edtech LLC, will be handled by Tutors contracted to provide sessions for the service (herein “Tutors”).

Article 1 (Scope of Application)

The policy covers the use and management of client information by tutors.

Article 2 (Information Shared with Tutors)

To allow Tutors to achieve the purposes of use as specified in article 3, they may receive the following information (herein "client information"), including personal information either directly from clients or from YO! INGLÊS:

• Information provided by clients in session requests
• Nickname
• Age
• Gender
• Profile Picture
• Video Recordings of sessions
• Audio Recordings of sessions
• Any other information provided by clients during sessions
• Any other client information gained while conducting sessions

Article 3 (Purpose of Use)

Tutors will handle client information solely for the following purposes:

• To provide and manage sessions of the service.
• To communicate with clients.

Article 4 (Safety Control Measures)

Tutors have to carefully handle client information they receive to ensure it is not leaked to 3rd parties. Specifically, Tutors are required to follow the following rules to protect client information:

• Tutors should only access a client’s information when preparing for their sessions, conducting their sessions, writing session notes for them, or when asked to help resolve issues with their sessions as requested by DMM staff or their representatives.
• Tutors are not allowed to keep copies of client information, either physically or digitally, with the exception of the notes saved on the “Session Page” on the Tutors’ website.
• Tutors are not allowed to post client information on social media sites or on any other websites.
• Tutors will not disclose client information to 3rd parties except YO! INGLÊS staff or their representatives unless legally obligated to do so.
• Tutors are not allowed to share their login ID and Password to the Tutors’ website.
• If Tutors become aware of the possibility that client information has been leaked, they are required to report this to the Tutor Support Team immediately. And in the case of a security incident, they are required to the best of their ability to help YO! INGLÊS staff or their representatives to resolve the issue.
• For violations of all other provisions provided in this Client Information Policy for Tutors, Section 13. PENALTIES. of the Tutoring Services Agreement shall apply, notwithstanding the filing of other cases under American Law.

Article 5 (Inquiries)

If Tutors have any questions, opinions, complaints, or any other inquiries regarding the handling of client information, they should contact the Tutor Support Team at [email protected].

Last updated: January 8, 2025.

RETENTION OF PERSONAL DATA

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will delete it.

For candidates who wish to withdraw their application, request the deletion of their information or do not advance in the selection process, we will delete their data except for the following:

• Name
• Nationality
• Email address
• Passport scan (for identification purposes only)
• 1 assessment video
• Interview video recordings

The above information will be retained for 12 months after requesting or withdrawing from the selection process. The purpose of this is to monitor and prevent fraud reapplications of applicants. All other information not mentioned will be deleted permanently.
If we have grounds for retention and processing of your data other than just your consent and any of the purposes for processing listed in section 4 (Our Purposes For Processing Your Personal Data) still apply, we reserve the right to decline to delete your data even if you withdraw your consent. In this case your data will be deleted when either those other grounds expire or when the purposes no longer apply.

LOCATION INFORMATION

We store the IP addresses of computers accessing our services but not the exact location of the computer being used.

TRACKING OF USER ACTIVITY

Our application was designed for the purpose of video calls and chats in conducting the session.
Our application incorporates a system that allows the yosers and tutors to interact with the website together. Any navigation made in the website either by any of the parties is visible to both. If someone types, highlights, makes changes, etc. within the application, we will also be recording all of these data for the same purposes as stated above.

• We use tracking tools such as Google Analytics

Cookies
We use "cookies" to collect information about your activity on our website. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive. You can instruct your browser to refuse all cookies. However, if you do not accept cookies, you may not be able to use some portions of our web site.

• We serve ads on our website with Google AdSense

DoubleClick Cookies
Google, as a third party vendor, uses cookies to serve ads on our website. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our clients based on their visit to our web site or other web sites on the Internet. You can opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page.

LINKS TO OTHER SITES

Our website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's website. It is important that you review the Privacy Policy of every site you visit. We have no control over, and are unable to assume any responsibility for, the content, privacy policies or practices of any third party sites or services.

CHANGES TO THIS TUTOR PRIVACY NOTICE

We may update our Tutor Privacy Notice from time to time. We will notify you of any changes by posting the notice on this page. Please revisit this page periodically for any changes. Changes to this notice are effective when they are posted on this page.
If you have questions about this notice and requests, you can contact us at:
[email protected]

Any query or complaint should include at least the following details:

• Full name and email address.
• A brief description of your query or complaint.

If you have any concerns or questions unrelated to this notice, please contact [email protected].