Effective Date: 1st January, 2018.
- Collection of Personal Information
Subject to creating a User account in accordance with our Terms and Conditions, at the time of registration, you will be required to provide information about yourself, which may include, but is not limited to, (a) personal information, such as your name, gender, date of birth; (b) contact information, such as your email address, phone number, etc.; (c) educational background, interests and/or tutoring preferences and other personal information or tutoring related information that you choose to share with us or that is required to allow us to provide the Services to you (collectively, the “Personal Information”). You may still access and use some of the Services if you choose not to provide us with any Personal Information, but some features of the Services may not be accessible to you if you choose not to provide us with the required Personal Information.
We also may collect non-personally identifiable information about you, such as information regarding your use of the Services, your IP address, usage statistics regarding the Services, time stamps, browsing history, general geographic location, type of device you use to connect to the Services, type of operating system you use (e.g., Microsoft Windows, Google Chrome OS, Mac OS, Android or iOS), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer, Safari), the domain name of your internet service provider, and information regarding your Internet location when you see Douroosi’s ads and whether you click on such ads. We also may receive certain aggregated or anonymous information regarding users of the Services such as the age, gender, occupation, zip code, interests, and language preferences of Users of the Services, as well as information collected through questionnaires and surveys. If you are using the Services, we may collect additional non-personally identifiable information about your device such as hardware model, distinctive identifiers for your device (e.g., MAC address, IMEI number, IMSI number, etc.) certain of your selected settings with respect to your device, and the cellular carrier that provides your device with cellular services. “Non-personally identifiable information” refers to information that does not personally identify the individual to whom the information relates, such as information that is aggregated by Douroosi or a third party, or information that is not linked to contact information or other personally identifiable information of an individual.
In the event that any of the non-personally identifiable information that we collect about you is maintained, used or shared in a manner that associates it with your name, contact information or other personally identifiable information, it will be treated as personally identifiable information. If you are logged into an Account on Douroosi, information such as the content you access, view, click on, download or search for when on the Services, the devices from which you access such content and the length of time for which you view same and other information regarding how you access, browse and use the Services, may become personally identifiable. In such an event, Douroosi will treat such information as personally identifiable information.
- Collection of Billing Information
- Collection of Traffic Data
We may automatically collect certain data when you use the Services, such as (a) IP address; (b) domain server; (c) type of devices used to access the Services; (d) web browsers used to access the Services; (c) webpage or other source through which you accessed the Services from; (d) geolocation information and other statistics and information associated with the interaction between your browser or device and the Services (“Traffic Data”).
- How We Collect Your Information
We collect information, including Personal Information, Billing Information and Traffic Data (“Collected Information”), when you use and interact with the Services, and in some cases from third party websites. Such means of data collection include the following:
- when you use the Services’ interactive tools and services, such as searching for Tutors and tutor’s availability.
- when you voluntarily provide information in free-form text boxes through the Services or through responses to surveys, questionnaires, ratings and other;
- if you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates, reminders, alerts or notices;
- if you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable;
- through cookies, web beacons, website analytics services and other tracking technology;
- when you use the “Contact Us” function on the Site, send us an email or contact us by any means.
- How We Use Your Collected Information
Douroosi only uses Collected Information to facilitate providing the Services, which includes searching for, scheduling and participating in tutoring sessions with Tutors. Douroosi may use Collected Information to send you notifications and other related activities to the Services, in addition to promotional offers from time to time. Aside from using such information to provide the Services, Douroosi may use them to help improve the Services, develop new Services, and to advertise for Douroosi on other websites or platforms. Specifically, such use may include but is not limited to any of the following:
- provide you with Services or information you inquire about or request;
- respond to emails and correspondences we receive from you;
- send you customized emails or to show you Sponsored Results;
- send you notifications about Services, Tutors, tutoring services or other resources and Content that may be of interest to you, according to your preferences;
- contact you for any activity related to the Services, such as sending you reminders for upcoming tutor sessions or notices regarding any activity occurring on your account;
- enhance your user experience, perform business analysis and improve or expand our Services; and
- prevent and investigate security cases and potential unauthorized or illegal activities.
- How We Disclose Your Information
- certain Personal Information may be shared or disclosed to your selected Tutors with whom you schedule tutoring sessions. Douroosi will only disclose personally identifiable information to facilitate communication between you and your Tutor.
- your Personal Information may be shared or disclosed to your relevant insurance company to determine eligibility, cost-sharing obligations, and obtain benefit plan information on your behalf.
- your Personal Information and Traffic Data may be shared or disclosed with third-party partners who perform necessary operational services, such as billing, data storage, insurance verification, security, Website analytics, and/or who make certain service features available to our Users.
- your information may be transferred or provided to another company in the event of a merger, sale, acquisition or change of ownership or control by or of Douroosi, whether in whole or in part. Upon such occurrence, we will make reasonable efforts to notify you before your information becomes subject to different terms and privacy policies.
- Douroosi may be required to disclose your Personal Information or any Collected Information if, upon Douroosi’s sole discretion in good faith, such disclosure is important to (a) comply with applicable laws, regulations, or court judgement; (b) protect any right entitled to you, Douroosi, or any other party; (c) enforce this Agreement; (d) to the extent necessary to respond to any action as a result of any posting or content that violates third-party rights.
In no event will any content in open reviews, ratings or online discussion be private and be treated as public information. Douroosi reserves the right to disclose such information in any way and by any means it deems appropriate. We encourage you to review any Personal Information you chose to disclose publicly, as Douroosi is unable to control any use of such information by third parties.
- How We Store and Secure Collected Information
Douroosi undertakes to perform all procedural, technological and necessary measures to meet strong data storage and security standards that are designed to help protect personal information from loss, unauthorized access, disclosure, alteration, or destruction, such as, but not limited to, firewalls, encryption techniques, and authentication procedures, among others, to work to maintain the security of your online session and personal information. Douroosi employs measures that are reasonable, a secure server is used to store Collected Information or any sensitive information you submit to us, protect its transmission through firewalls and encrypt it via Secure Socket Layer (SSL) technology. Douroosi performs disaster recovery, which implements nightly backups of all databases and our data is stored simultaneously at multiple, geographically distributed locations to ensure redundancy in the event of a natural disaster or other emergency. Transmissions over the Internet are never 100% secure or error-free. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal information to Douroosi or through Douroosi Services via the Internet. Although we attempt to securely store and safeguard your information, we do not guarantee the security of your information and cannot prevent any breaches by third parties. If we have reasonable doubts that your information has been compromised, we will try to promptly notify you of the situation
- SAFEGUARDING CHILDREN POLICY
A child is defined by Douroosi as any person who has not reached their 18th birthday irrespective of the age of majority in the country where a child is, or in their home country.
Children and young people under 18 years of age are an especially vulnerable group and therefore the law requires they must be specially protected from harm. Douroosi staff are therefore to act with common sense and care to ensure that children are protected from harm.
We also recognise that we have a fundamental duty of care towards all children where our programmes and operations facilitate contact with children or have an impact on children. This includes a duty to protect children from harm or risk of harm as a result of:
- misconduct by our tutors or partners
- poor practice
- the poor design or delivery of our lessons and operations.
Conversely, when things go wrong there needs to be a rigorous, objective investigation into of what happened and why, so that important lessons can be learnt, and services improved to reduce the risk of future harm to children.
Safeguarding is a term which is broader than ‘child protection’ and relates to the action taken to promote the welfare of children and protect them from harm. Safeguarding is everyone’s responsibility.
- Protecting children from maltreatment
- Preventing impairment of children’s health and development
- Ensuring that children grow up in circumstances consistent with the provision of safe and effective care and
- Taking action to enable all children to have the best outcomes
Harm is explained here:
Any person has committed an offence if they have:
Harmed a child or vulnerable adult through their actions or inaction (relevant conduct). This means a person has done something which may lead to harm or has failed to take action to prevent harm.
If you are aware you must act immediately and inform a Safeguarding officer at Douroosi. The safeguarding Officer for Douroosi is Jane Georgiou
Harm should be considered in a wider context than just physical and can take numerous forms.
Types of harm relating to children can include (but are not limited to):
- Emotional / Psychological – Action or inaction by others that causes mental anguish.
- Physical – Any intentional physical contact that results in discomfort, pain or injury.
- Sexual – Any form of sexual activity with a child under the age of consent.
- Neglect – Failure to identify and/or meet care needs.
Staff working with vulnerable groups, including children, must always act in their best interests and ensure they take all reasonable steps to prevent harm to them. Having safeguards in place within an organisation not only protects and promotes the welfare of children but also it enhances the confidence of staff, volunteers, parents/carers and the general public.
These safeguards should include a child protection policy and procedures for dealing with issues of concern or abuse and a safeguarding officer.
- Striving to Protect Children
Children shall not receive or come to harm or be placed at risk of harm by any act of neglect, failure to act, inadequate staff training or management or for any other reason within our control.
This policy is a statement of intent that demonstrates a commitment to safeguard children involved in learning or coming into contact with Douroosi in any other capacity, from harm. Key factors are:
- valuing, respecting and listening to children
- ensuring all necessary checks are made when recruiting staff
- maintaining strong child protection systems and procedures for staff
- training its staff and providing a common understanding of child protection issues to inform planning and practice
- sharing information about child protection and good practice with children and parents/carers
- sharing information about concerns with agencies who need to know, and involving parents and children appropriately
- providing effective management for staff through clear processes, supervision and support.
- All staff will comply with the associated policies and procedures which promote children’s safety and welfare e.g. with regards to: e-Safety, Equality & Diversity and Data Protection
We will provide adequate and appropriate resources to implement this policy and will ensure it is communicated and understood.
Douroosi will review this global policy statement annually to reflect new legal and regulatory developments and ensure good practice.