Effective Date: May 23, 2023

Welcome to Homeroom! Share Ave, Inc. dba Homeroom (“Homeroom”, “we” or “us”) is committed to respecting privacy of the information of its Users. This Privacy Policy forms part of, and is governed by the Agreement and explains how we collect, use, store and disclose the information of our Users. 

To know when the changes to this policy are effective, please review the “Effective Date” at the top of this page. 

When you read the Privacy Policy, you will come across certain capitalized terms. These capitalized terms which are not defined in this policy, will have the same meaning as set out in the Terms of Use, which you can view here. 

1. Privacy Policy 

What Section 1 is about: Section 1 specifies that this Privacy Policy applies to all Users when they access or use the Services. Section 1 also specifies that Homeroom may change this Privacy Policy, and all such changes will be effective from the specified date. If Homeroom makes substantial changes to this Privacy Policy, Homeroom will provide you notice. 

1.1 Who do these Terms of Use apply to?
‍This Privacy Policy applies to all Users.‍

1.2 How do I accept the Privacy Policy?
‍By accessing or using the Services, or by checking the box to confirm that you agree to our Privacy Policy, you confirm that you accept and agree to comply with the Privacy Policy, and to the collection and use of your Personal Information in accordance with this Privacy Policy and the Agreement. 

If you disagree with anything in this Privacy Policy or the Agreement, you should not use the Services.  

1.3 Will this Privacy Policy ever change? 
‍Homeroom may change this Privacy Policy from time to time, like when Homeroom offers a new Service, with changes in technology or when legal requirements arise, and you should review this page periodically. After each change to the Privacy Policy, Homeroom will send you an email notification and update the ‘Effective Date’ at the top of this page. 

If you continue to use the Services or provide Homeroom Information (defined below) after any change to the Privacy Policy, you are taken to have accepted the changes to the Privacy Policy from the ‘Effective Date’. 

2. What information does Homeroom collect about me? 

What Section 2 is about: Section 2.1 mentions that Homeroom will receive two types of information about you: (i) Personal Information (which can be used to identify you); and (ii) Non-Personal Information (which cannot be used to identify you). Section 2 also explains what information is Personal Information (Section 2.2), and what is Non-Personal Information (Section 2.3).

2.1 Types of information that we collect about you
Homeroom collects and receives the following types of information about you when you access or use the Services:

• Personal Information: Such information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”); and 
• Non-Personal Information: Such information which by itself cannot be used to identify or contact you (“Non-Personal Information”). 

We refer to the Personal Information and Non-Personal Information collectively, as Information.  

2.2 What Personal Information do we collect about you?
‍Homeroom may require you to provide, or collect the following Personal Information from you:

• Identifiers such as your first and last name, any photographs or video recordings voluntarily uploaded by you on the platform, Student’s name, grade, and school in which Student studies, name of Student’s day teacher at school and his or her age or date of birth. Your contact information such as your email, phone number and geographical location along with any notes about Student that you may provide to Provider; 
• ‍Internet or your connection related information such as your Internet Protocol (“IP”) address and mobile device unique identifier;
• ‍Commercial Information such as information about your credit or debit card or other financial account information required to process payment for the Services;
• ‍Audio, visual, or similar information such as video recording of Students, any audio and videos that are uploaded by Users, such as by Provider at the time of registration etc.;
• ‍Professional or employment related information of Providers such as skills that Providers possess and their qualifications and certifications; and
• ‍Other Information that allows you to be identified personally such as information related to the Activities purchased by you, or Activities conducted by you using our platform. This also includes information that we collect from the social media ‘accounts linked to your account.

2.3 What Non-Personal Information do we collect about you??
‍Homeroom may collect Non-Personal Information about you such as your age, zip code, information about where Students will disperse after their Activities etc. 

The limitations and requirements contained in this Privacy Policy only apply to collection, use, disclosure, transfer and storage, or retention of Personal Information by Homeroom, and not to Non-Personal Information. 

Homeroom may combine your Non-Personal Information with information of other Users to improve the Services. At times, Homeroom may also amalgamate your Personal Information with other Non-Personal Information we have about you (including Non-Personal Information that Homeroom collects from third parties) to offer you a better experience. In such event, Homeroom will treat the combined data as your Personal Information until such time as it can no longer be associated with you or used to identify you.

2.4 Does Homeroom collect Personal Information about third parties from you?
Homeroom may collect information about you via a third-party, like your friend referring you to try Homeroom, and we will use that information to contact you. 

3. How does Homeroom collect my Information? 

What Section 3 is about: Section 3 specifies the sources from which Homeroom collects your Information. Homeroom receives your Information from three sources: (i) you; when you voluntarily provide the Information to Homeroom – Section 3.1; (ii) the computer, mobile device, and the Internet browser which you use to access the Services (Automatic Data) – Section 3.2; and (iii) from other sources such as from the social media accounts which you link to your Homeroom account – Section 3.3. 

3.1 Information you provide to Homeroom
Homeroom collects all Information which you voluntarily provide to Homeroom by using the platform or interacting with Homeroom. This includes but is not limited to, Information that you provide to Homeroom in the following instances:

• Register and operate your account: Homeroom receives Information when you register with Homeroom, update your account, and when you close your account with Homeroom; 
• Communicate with Homeroom: Such as when you contact Homeroom support, or when you communicate with a Provider or other Parents & Guardians using chat, audio or video call facility offered by Homeroom or any third-party communication service provider of Homeroom; 
• ‍Use social media platforms: Such as when you link your social media accounts to your Homeroom account. Homeroom will use the Personal Information you have provided to the social media platform to create your account, and to enable you to access your Homeroom account; 
• ‍Use the Services: Such as when you purchase and book any Activities, or when you create, offer, and conduct any Activities;
• ‍Through audio, visual, or similar medium: Such as through any documents, audio, or video messages that Providers may upload about themselves on the platform;
• ‍Set-up payment instructions: Commercial Information such as your credit or debit card information or other financial account information that you provide Homeroom when you set-up payment instructions for the Services; and
• ‍Participate in any promotional activities and referral programs conducted by Homeroom. 

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3.2 Information Homeroom automatically collects about you
‍Homeroom automatically collects certain Information about you that gets sent to Homeroom from the computer, mobile device and, and the Internet browser through which you access the platform (“Automatic Data”).

Automatic Data includes but is not limited to, the following Information: 

• Your IP address;
• Information about the device you use to access the platform;
• The web address or the advertisement that brought you to Homeroom;
• The terms that you searched on a search engine that brought you to Homeroom;
• Statistics about your use of the platform, such as the links you clicked on, the time and date of your visit, the content that you viewed and duration of your stay on the platform; 
• Times taken by you to download any content and information from the platform; and
• Details of the Activities you have enquired about, or purchased and booked, and any information that Homeroom needs to respond to your queries. 

Homeroom collects Automatic Data based on your consent, which you provided when you registered as a User and accept this Privacy Policy. 

How is Automatic Data collected? 
Homeroom, its marketing partners, analytics, and service providers use small files that store information on the device you use to access the Services called cookies, and other tracking technologies to collect Automatic Data. Homeroom uses Automatic Data to identify different Users, improve browsing experience of the Users and to generally understand the online behavior and interests of people who interact with Homeroom. To know more about how Homeroom uses cookies, please see Section 22 of this Privacy Policy. 

3.3 Information about you that Homeroom obtains from others
Homeroom may also collect or receive Information from the social media platform that you use to log-in to your account or from any service providers that Homeroom uses. Homeroom may combine this information with information that Homeroom already has about you. This helps Homeroom to update, expand and analyze its records, identify new customers, and create more tailored advertising that may be of interest to you.  

4. For what purposes does Homeroom collect my Information? 

What Section 4 is about: Section 4 mentions that Homeroom may use your Information to provide Services, maintain and improve the Services, provide new services, personalize the Services for you, send you marketing communications, comply with law, and enforce the Agreement etc. 

4.1 Homeroom uses the Information Homeroom collects from you for the following purposes:

• Provide the Services: Homeroom uses your Information to deliver the Services, like to enable you to register your account, to facilitate Parents & Guardians and Schools to search and book Activities, and for Providers to create, market and sell Activities, and to process payments for Services;  
• Maintain and improve the Services: Homeroom uses your Information to make sure that the Services work as intended, such as troubleshooting issues that you report to Homeroom, and to provide customer support as needed. When you contact Homeroom, we will keep a record of your request to solve any issues you might be facing; 
• Develop new services: Homeroom uses your Information to develop new services with the hope that they benefit you;
• Provide personalized Services, including content: Homeroom uses your Information to customize the Services for you, like showing you relevant results when you search the platform and to provide you recommendations; 
• Protect against security threats, abuse, and illegal activity: Homeroom cares about keeping you secure and safe while using the Services. Keeping you safe requires Homeroom to process your Information such as your device information, monitor your activity on the platform and other relevant information. Homeroom uses this information to combat spam, malware, malicious activities, security risks and to verify your identity so that unauthorized users are not able to access your Information; 
• Measure performance: Such as for analytics and measurement to understand how the platform and the Services are being used. For example, Homeroom analyzes data about your visit to the platform to better design the platform and the Services to improve your experience; 
• Marketing communications: In accordance with your communication preferences, Homeroom will occasionally contact you to announce new services and features Homeroom builds for you, share tips for using the Services, make offers and provide information on how you can use the Services. If you wish to stop receiving marketing emails, please follow the instructions contained in the emails to opt-out of receiving further email marketing communications from Homeroom; 
• Comply with law: The Services are subject to certain laws and regulations. Homeroom also uses your Information to satisfy applicable laws or regulations, and discloses Information in response to legal process or requests from government and law enforcement agencies; and
• Enforce the Agreement: Your use of the Services is subject to the Agreement. To ensure that you comply with the Agreement, Homeroom processes your Information to investigate, prevent or reduce violations of the Agreement. 

Homeroom may also use your Information for other purposes. Homeroom will inform you and ask for you consent before using your Personal Information for a purpose that is not covered by this Privacy Policy. 

5. To whom does Homeroom disclose my Information? 

‍What Section 5 is about: Section 5 describes that Homeroom may share your Information with its employees, agents, professional advisers, sponsors, payment service providers and third parties etc. Homeroom does not rent or sell information for marketing purposes.  

5.1 Homeroom is not in the business of selling or renting your Information. Homeroom may share your Information with the following persons or entities, all of whom may use your Information only for the purposes described in the Privacy Policy. 

• Homeroom employees and other companies owned or controlled by Homeroom;
• Third party suppliers and service providers (such as service providers whose services Homeroom uses to deliver the Services to you, customer management services who process data on behalf of Homeroom, or third-party advertising networks so that they can deliver Homeroom advertisements to you across the Internet); 
• Professional advisers and agents of Homeroom;
• Payment system operators whose services are required to process payments for Services (e.g. merchants receiving card payments such as Stripe);
• Our tax compliance service providers;
• Our existing or potential agents or business partners;
• Sponsors or promoters of any promotional activity that Homeroom carries on the platform; 
• In the event of a merger, sale, or reorganization of all or part of our business, Information covered by this Privacy Policy may be transferred in connection with that deal; and
• Third parties, whenever you specifically consent or direct Homeroom to share the Information.

5.2 Sharing aggregate and anonymous Non-Personal Information

Homeroom may aggregate Non-Personal Information about Users and share it with third parties. Though this information will be anonymous and will not identify any User personally, in some cases the third parties may be able to combine this information with other data they have about you, or that they receive from other parties, in a manner that allows them to identify you personally.  

6. How does Homeroom collect, use, and disclose Personal Information relating to children?

What Section 6 is about: Section 6 describes Homeroom’s privacy practices for Personal Information relating to children below 13 years of age like the child’s first name, second name and notes for Providers etc. (“Children’s Data”). This Section explains how Homeroom obtains consent of the School Organizers and the Parents and Guardians’ for collecting Children’s Data, the way Homeroom collects, uses, and discloses Children’s Data, and the control that Parents & Guardians  exercise over Children’s Data. 

Homeroom’s collection, use and disclosure of Children’s Data is governed by the Agreement and all applicable laws relating to the collection of Children’s Data, like COPPA. Homeroom does not sell any Children’s Data to third-parties. 

6.1 Collection of Children’s Data 

School Organizers
‍Homeroom allows School Organizers to register themselves for the Services. Through the course of providing its Services to School Organizers, Homeroom may have access to Children’s Data that is provided by the School Organizers, by Parents & Guardians or by Students themselves. 

The School Organizers also authorize Homeroom to collect Children’s Data through the Services. For example, Homeroom receives child’s first name, last name, grade, and notes about the child in the process of booking the Activities. 

Homeroom keeps Children’s Data confidential and does not use Children’s Data for any purpose other than to provide the Services in accordance with the Agreement. 

‍Parents & Guardians
‍Homeroom collects Children’s Data directly from Parents & Guardians or from the Children during Activities.  

Homeroom does not allow children to post any Personal Information about themselves on the platform, or collect any Personal Information directly from the children, until they participate in the Activities.

6.2 Use and disclosure of Children’s Data ‍

Homeroom shares necessary Children’s Data with Providers to enable them to conduct the Activities. Homeroom may also share Children’s Data with other third parties in response to any instruction, or authorization that Homeroom receives from the School Organizers, or Parents & Guardians.  

Like other Personal Information that Homeroom receives from you, Homeroom may also share Children’s Data in accordance with Section 5 with its employees, vendors, service providers, following any transfer of its business, and to comply with its legal obligations.

Bear in mind that Homeroom cannot control or monitor what Personal Information your child shares with Providers and the other Students who participate in the Activities with your child, nor what these third parties ultimately choose to do with such Personal Information.  You agree that Homeroom disclaims all liability in that regard. 

6.3 Consent of School Organizers and Parents & Guardians to collect Children’s Data

Where School Organizers register themselves for the Services, Homeroom relies on each School Organizer for the following: 

• To provide appropriate notice to Parents & Guardians about the School Organizers’ use of Homeroom;
• To provide their consent, and to authorize Homeroom to collect Children’s Data; and 
• To obtain necessary permission from Parents & Guardians to release Children’s Data to Homeroom in case Students are enrolled for the Activities by the School Organizers. For example, in case of Students who receive scholarships.  

Where Parents & Guardians register themselves on the platform, Homeroom obtains verifiable consent of the Parents & Guardian’s before collecting Children’s Data. Homeroom does not knowingly collect any Children’s Data unless and until the Parents & Guardian’s allow their children to use the Services. 

If Parents & Guardians do not consent, Homeroom will neither collect, use, or disclose Personal Information relating to their child, nor allow their child to use the Services.

Please contact Homeroom at hello@homeroom.com if you believe Homeroom has inadvertently collected Personal Information of a child under 13 without proper consent, so that we may delete such information as soon as possible.

6.4 Parental Control and choices regarding Children’s Data‍

As a Parent & Guardian, you can update the Children’s Data Homeroom has about your child by logging-in to your account. You can also email Homeroom at hello@homeroom.com to access, update or delete any Children’s Data about your child.  Homeroom will honor all your requests within a reasonable time. 

As a Parent & Guardian, you can also refuse to permit Homeroom from collecting any Children’s Data for your child(ren). Since Children’s Data is required to book the Activities, without Children’s Data, Parents & Guardians will not be able to book the Activities. You can also ask us to delete all Children’s Data that we have for your child(ren) in our records. Bear in mind that a request to delete your Children’s data may result in deactivation and ultimately closure of your account. 

Homeroom is also entitled to delete the Children’s Data about your child, when Homeroom reasonably believes the such information is no longer needed. 

7. How does Homeroom use my Personal Information for marketing?

What Section 7 is about: Section 7 explains that Homeroom may use your communications with other Users and any User Content and Feedback provided by you for marketing purposes. 

7.1 Communications data
‍Homeroom enables (or may enable in the future) Users to communicate with each other and with Homeroom using text messages, audio, and video calls and in app messages and calls, using the platform and, or third-party communication services. 

Homeroom and the third-party communication service providers providing these communication services may monitor, collect, record, store and use the details and content of the communications and the related Personal Information.

All Users have the right to request that Homeroom cease to use any communication involving them and, or their Personal Information for marketing purposes.  

7.2 Feedback and User Content uploaded by Users 
‍Homeroom may use the whole or any part of any Feedback and User Content uploaded by the Users on the platform.

All Users have the right to request that Homeroom cease to use any Feedback or User Content involving them and, or their Personal Information for marketing purposes.  

Does Homeroom respond to legal requests for my Information? 

What Section 8 is about: Section 8.1 specifies that Homeroom may disclose your Information to government authorities to comply with subpoenas etc. 

Section 8.2 specifies that Homeroom may disclose your Information to third parties to assist in investigations, or where disclosure is required because of Homeroom’s legal obligations. 

8.1 Sharing your Information in response to court orders and subpoenas
‍Homeroom will disclose your information to law enforcement or other governmental authorities where Homeroom believes disclosure is required to comply with warrants, court orders, subpoenas, or other lawful government requests. 

Homeroom narrowly interprets information requests and will only disclose Information that has been specifically requested or where you provide your explicit consent.

8.2 Sharing your Information with third parties 
‍Homeroom may also share your Information with third parties as Homeroom believes in good faith is necessary to investigate or act regarding illegal activities, suspected fraud, or potential threats against persons, property, or the systems on which we operate the Services, or as otherwise necessary to comply with Homeroom’s legal obligations.

9. How can I manage my Information stored with Homeroom? 

What Section 9 is about: Section 9 specifies that Users can access, correct, update, or delete their Information by emailing Homeroom. 

9.1 You are responsible for maintaining the accuracy of the Information you submit to us, such as your contact information. 

9.2 In most cases, you can manage your Information simply by logging into your account and directly editing your information. 

9.3 If you prefer, you can also contact Homeroom at hello@homeroom.com to ask us to provide access to, correct, update, or delete your Personal Information. If you request to access the Personal Information you have submitted, Homeroom will respond to your request within 45 days or as required by law. Please note that Homeroom may ask you for proof of account ownership and, or identity before fulfilling your request.

9.4 If you are a California resident please visit the “Privacy Rights of California Residents” in Section 20 of this Privacy Policy to know about your rights and how to exercise them. 

10. How does Homeroom secure my Information? 

What Section 10 is about: Section 10 specifies that Homeroom takes several steps to protect your Information, but its security is not guaranteed. 

10.1 Homeroom takes commercially reasonable physical, administrative, personnel and technical measures to secure your Information. Unfortunately, no method of transmission over Internet, or form of electronic storage is completely secure. As a result, though Homeroom strives to protect your Information, Homeroom cannot ensure and does not warrant the security of your Information that is held by Homeroom. 

10.2 Any transmission of Information is at your risk. Homeroom is not responsible if any User circumvents any privacy settings or security measures contained on the platform. 

11. Where does Homeroom store my Information?

What Section 11 is about: Section 11 specifies that Homeroom being an American company, stores your Information in the United States. Homeroom’s service providers may process and store your Information elsewhere. 

11.1 We will store and process your Information in the United States. Our service providers may store and process your Information in the United States and elsewhere where they maintain facilities. 

11.2 You consent to the transfer of your information to the United States or any other country in which Homeroom, other companies owned or controlled by Homeroom and their service providers maintain facilities.

12. Links to other sites

What Section 12 is about: Section 12 specifies that the Services may contains links to other websites. Users are urged to read the privacy policies of the other websites they visit. 

12.1 The Services contain links to third-party websites, which if you click will take you to these third-party websites. Homeroom does not exercise any control over these third-party websites. Homeroom also does not endorse, authorize, or make any representation about these websites or their privacy and information protection policies.  

12.2 These websites may place their own cookies or other files on your computer or mobile device, collect data or solicit Information from you. Homeroom encourages you to read the privacy policies or statements of these websites when you visit them.

13. Is my profile public?

13.1 Currently, Providers do not have the option to make their profile private. As a result, a profile that a Provider creates on our platform will be publicly visible.
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14. Personal Information provided to others 

What Section 14 is about: Section 14 specifies that this Privacy Policy only applies to Personal Information provided to Homeroom and not to other Users. 

14.1 This Privacy Policy does not apply to any Personal Information that you provide to another User or visitor through our platform, such as posting the Personal Information in the public areas of our platform. For example, any Feedback that you provide to another User or Personal Information that you post in your public profile are not in our control and are therefore, not subject to this Privacy Policy. 

15. Can I ask Homeroom to delete my Personal Information?

What Section 15 is about: Section 15 specifies that all Users may request deletion of Personal Information Homeroom has about them. 

15.1 All Users can request deletion of all Personal Information Homeroom has about them. 
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15.2 Homeroom will use commercially reasonable efforts to honor your requests for deletion of your Personal Information. Bear in mind that not all Personal Information can be deleted and that certain Information will continue to remain on the Services even after you close your account, for example any Feedback that you publicly posted. 

15.3 Please note that your right to request deletion of your Personal Information may be limited. For example, if you ask Homeroom to delete information, that Homeroom is required to retain by law, or which Homeroom has a compelling legitimate interest in keeping (such as for fraud prevention purposes).   

15.4 If you request Homeroom to delete all your Personal Information, then your account may become deactivated. If your account is deactivated or you close your account, you will no longer be able to use the Services or avail the Activities.  

16. What happens if I want to stop using Homeroom or close my account? 

What Section 16 is about: Section 16 specifies how you can close your account and that Homeroom may retain certain Personal Information of a former User for a commercially reasonable time as necessary. 

16.1 If you do not wish to continue using Homeroom, please contact Homeroom at hello@homeroom.com, and we will help you to close your account. Please remember that you will not able to use the Services after closure of your account. 

16.2 Even after closure of your account, Homeroom may retain your Personal Information for a commercially reasonable time for back-up, archival, legal, tax or audit purposes and for legitimate and lawful business purposes.  

16.3 In addition, any Personal Information that you have shared with other Users through the Services or with social media sites cannot be deleted. 

17. What happens if my account is inactive? 

What Section 17 is about: Section 17 specifies that Homeroom may close an inactive account. ‍

If your account is inactive for an extended period, Homeroom may close your account to comply with its legal obligations, and in accordance with its data retention policy. If that happens, Homeroom will try to notify you before taking any action.

18. Can Homeroom close my account?

What Section 18 is about: Section 18 specifies the instances in which Homeroom may close your account. 

18.1 Homeroom may close your account if your account is inactive for an extended period, you breach the Agreement, if we discontinue or materially modify a part of the Services, or in case we experience unexpected technical or security issues. You will not be able to use the Services after your account is closed. 

18.2 After closure of your account, Homeroom may retain your Personal Information for a commercially reasonable time for back-up, archival, legal, tax or audit purposes and for legitimate and lawful business purposes.  

18.3 Please note that any Personal Information that you have shared with other Users through the Services or with social media sites cannot be deleted, and will continue to be public even after your account is closed. 

19. Can I opt out of receiving marketing communications?

What Section 19 is about: Section 19 specifies that Users have the right to opt-out of receiving marketing communications from Homeroom. 

19.1 A registered Homeroom User can choose what communications they want to receive from Homeroom and, or third-party service providers of Homeroom. These communications may be in the form of SMS, emails, or other forms of communication. 

19.2 Users may opt-out of receiving marketing related text messages by emailing Homeroom at hello@homeroom.com. 

Users may also opt-out of receiving marketing related emails by emailing Homeroom at hello@homeroom.com, or by unsubscribing using the unsubscribe link provided in these emails. 

19.3 Homeroom reserves the right to continue to send you certain communications like, administrative and service messages, any information that you may request, even after you opt-out from receiving marketing communications.  

20. Privacy Rights for California Residents 

What Section 20 is about: Section 20 specifies that Users residing in California have been provided certain additional rights with respect to their personal information under the California Consumer Privacy Act. Such Users have the: (i) Right to know; (ii) Right against discrimination; (iii) Right to access their Personal Information; (iv) Right to ask for deletion of their Personal Information; and (v) Right to opt out of having their Personal Information sold.

All these rights are subject to exception and Users can exercise these rights by emailing Homeroom at hello@homeroom.com.

20.1 Users residing in California have been provided certain additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.). If you are a California resident, these terms and conditions apply to you.

20.2 Homeroom uses and collects your information for the purposes described in this Privacy Policy, which include “business purposes” under the CCPA. Homeroom makes the following additional disclosures relating to the collection, use and disclosure of your Personal Information under the CCPA. 

20.3 Users residing in California have additional rights in the Personal Information that Homeroom collects about them. These rights are discussed in Sections 20.4 to 20.8. All these rights are subject to certain exceptions. For instance, Homeroom will not be required to disclose your Personal Information if Homeroom is unable to verify your identity, or if Homeroom has already provided Personal Information to you during the 12 months preceding the receipt of your request in accordance with CCPA. 

20.4 Right to Know 

You have the right to request the following information about you in writing: 

Categories of Personal Information collected by Homeroom
In the preceding 12 months, Homeroom collected the following categories of Personal Information about you: 

• Identifiers such as your first and last names, email address, phone number, IP address, unique device identifiers or another online identifier;
• Commercial information such as your payment information and related information to enable you to pay for the Services, information about the Activities you purchased or considered to book;
• Internet or your connection related information such as the name of your internet provider, Internet browser type and version, your IP address;
• Electronic, audio, visual or similar information such as photos and videos uploaded by Providers and recordings of the Activities;
• Professional or employment related information (such as those provided by Providers); and
• Other information that relates to or is capable of being associated with you.

For additional examples of the types of Information that Homeroom collects, see Section 2 “What information does Homeroom collect about me?”.  

Business or Commercial purposes for collecting your Personal Information
Homeroom collects your Personal Information for the business and commercial purposes described in Section 4 “For what purposes does Homeroom collect my Information?”.

Categories of sources from which Homeroom collected your Personal Information 
‍Homeroom collects your Personal Information in the following manner: (i) directly from you when you use the Services; (ii) automatically when you use or access the Services, and (iii) from third-party sources described in Section 3 “How does Homeroom collect my Information?”.

Categories of Personal Information Homeroom has disclosed about you
In the preceding 12 months, Homeroom has disclosed the following categories of your Personal Information for business or commercial purposes: identifiers, commercial information, internet or other electronic network information, and geolocation data.

Categories of third parties with whom Homeroom shares Personal Information
‍Homeroom shares your Personal Information with third parties as described in the Section 5 “To whom does Homeroom disclose my Information”.

20.5 Right against Discrimination

You have a right to receive the same Services and price as other Users and cannot be discriminated against for exercising any of the rights described in Sections 20.4 to 20.8. Homeroom will not discriminate against you in any manner for exercising any of these rights.

20.6 Right to access your Personal Information
‍You have the right to request access to the specific pieces of Personal Information Homeroom has collected about you in the last 12 months. ‍

20.7 Right to ask for deletion of your Personal Information: You have the right to ask Homeroom to delete any Personal Information that Homeroom has collected about you. This right is subject to certain exceptions and Homeroom may retain your Personal Information where Homeroom cannot verify your request, or where Homeroom needs to retain the Personal Information to comply with its legal obligations, etc. 

20.8 Right to opt-out of having your Personal Information sold 

You have the right to opt-out of having your Personal Information sold. To clarify, Homeroom does not sell your Personal Information.

20.9 How do you exercise your rights?

Users residing in California may exercise these rights by emailing Homeroom at hello@homeroom.com. Please note that Homeroom may ask you for proof of account ownership and, or identity before completing your request. Homeroom will only use such Information to verify your identity, and for fraud prevention or security purposes.

21. Note for our European Users 

What Section 21 is about: Section 21 explains the data access rights available to European Economic Area (“EEA”), UK and Swiss individuals. 

21.1 Homeroom processes Personal Information originating from Users residing in the EEA, Switzerland, and the United Kingdom, on one of the following three grounds: 

• You have provided us your consent (which you are entitled to withdraw at any time);
• It is a contractual necessity; and
• The processing is in our legitimate interest in providing the Services. 

21.2 How long does Homeroom retain my Personal Information? 
‍Homeroom retains your Personal Information until you ask Homeroom to delete it, or till the time your Homeroom account is operational. 

After closure of your account, Homeroom may retain residual copies of your Personal Information for up to 18 months for legal, tax or audit purposes and for legitimate and lawful business purposes.  

Please note that any Personal Information you share with other Users through the Services or with social media sites cannot be deleted, and will continue to be public even after your account is closed. 

21.3 What are my rights in the Personal Information that you hold about me? 
‍You have certain rights in the Personal Information we hold about you. These include the following rights:

• Right to ask for copy of your Personal Information;
• Right to seek rectification or deletion of your Personal Information; and
• Right to unsubscribe from marketing communications. 

To exercise any of your rights, please email Homeroom at hello@homeroom.com. 

Do note that there may be instances where Homeroom is not legally required to honor your request. This could be because of the laws of the place where you reside, or because the law exempts us from doing so. We will assess all your requests on a case-by-case basis, and notify you accordingly. 

21.4 What happens if I want to stop using Homeroom, or if Homeroom closes my account?
‍If you wish to stop using Homeroom, please contact Homeroom at hello@homeroom.com and we will help you to close your account. 

After your account is closed, Homeroom may retain residual copies of your Personal Information for up to 18 months for legal, tax or audit purposes and for legitimate and lawful business purposes.  

Please note that closure of your account does not affect any Personal Information you may have shared with other Users through the Services or with social media sites. Such Personal Information cannot be deleted, and will continue to be public even after your account is closed. 

21.5 Where does Homeroom store my Personal Information?
Homeroom stores and processes your Personal Information in the United States. Our service providers may store and process your Personal Information in the United States and elsewhere where they maintain facilities. 

By using the Services, you consent to the transfer of your information to the United States or any other country in which Homeroom, other companies owned or controlled by Homeroom and their service providers maintain facilities.

Since, data privacy laws or regulations in your home country may differ from, or grant more protection than, those in the United States, whenever we transfer Personal Information outside of the EEA, Switzerland, or the UK, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Information.

21.6 In what capacity does Homeroom act vis-à-vis my Personal Information?
‍Homeroom acts as ‘Data Controller’ in respect of your Personal Information.

22. Cookie Policy 

What Section 22 is about: Section 22 specifies the technologies, which include cookies, pixels, web beacons and gifs (collectively “Cookies”). This policy explains the different types of Cookies that Homeroom uses on its platform and how you can control them. Where applicable, we provide you with the opportunity to opt-out. 

22.1 What are Cookies? 
‍Cookies are small text files that each website that you visit sends to your computer, mobile device, or browser. Cookies are stored on your computer or mobile device.  

22.2 What are Cookies used for? 
‍Cookies help the website remember information about your visit, like things that you viewed or searched on the website, help remember your preferences, etc. This makes your next visit to the website easier and the website more useful to you. 

Homeroom uses Cookies for many purposes. For example, Homeroom uses Cookies to remember your search preferences, to protect your data and to make the ads you see more relevant to you.  

22.3 What type of Cookies does Homeroom use? 
‍Homeroom broadly uses four types of Cookies. You can read more about each type of Cookie below. 

• Essential: These Cookies are essential for you to able to experience the full functionality of our platform. These Cookies allow you to log-in to your account, add Activities, and checkout securely, besides allowing you to edit your Homeroom account. These Cookies allow Homeroom to maintain user sessions and prevent security threats. Without these Cookies, you will not be able to properly access and use our platform. 
• ‍Functionality Cookies: Functional Cookies allow Homeroom to remember the choices you make on the Homeroom platform and to provide you an enhanced and more personalized experience, like helping Homeroom remember your User name, the region you are in and assisting you during log-in. These Cookies also help Homeroom remember any pages that you customized, and provide services you request such as viewing photos, videos or providing any Feedback.  
• ‍Performance Cookies: The main purpose of performance Cookies (also called analytics Cookies) is not to identify you, but to collect information about how you use our platform. For example, performance Cookies show Homeroom which pages you view most frequently on our platform, the types of Activities that you are most interested in, and help Homeroom take note of any difficulties that you faced while using the platform. Performance Cookies also show Homeroom whether our advertising is effective or not. All this information is collected on an anonymous basis and is used to improve your visit to the Homeroom platform.
• Targeting or advertising Cookies: These Cookies can remember that your device has visited a website or service, and can also track your activity across other websites and services, besides Homeroom. Homeroom may share the information collected by these Cookies with its service providers, such as advertisers who may use this information to show you advertisements that Homeroom believes are more relevant to you and your interests. These Cookies may also be used by our service providers to measure the effectiveness of our advertising campaigns.

22.4 Third-party analytics providers, ad servers and similar third parties
‍Homeroom may use third-party service providers to monitor and analyze the use of its platform. For example, Homeroom may use a product analytics service provider to collect Information about how you use the Services, which part of the Services you frequent most, and the time you spend using the Services etc. Homeroom may also use marketing service providers who use information about your visit to other websites to target advertisements for the Services. The third-party service providers engaged by Homeroom may use Cookies to collect Information about you. Homeroom may not always control the type of Information these third-party Cookies collect and store about you.

22.5 How long will the Cookies stay on my device?
‍The length of time a Cookie will stay on your device will depend on the type of Cookie. If the cookie is a ‘session’ Cookie, it will stay on your device until you stop browsing. A ‘persistent’ Cookie on the other hand will stay on your device till the cookie expires or is deleted. 

22.6 How do I control Cookies? 
‍You may refuse to accept Cookies from our platform at any time by activating the setting on your browser which allows you to refuse Cookies. These instructions are usually located within the “Help”, “Tools” or “Edit” facility. Some third-party websites or applications also provide the option to reject Cookies, by allowing you to opt-out. 

Please be aware that if Cookies are disabled, not all features of our platform may operate as intended.

23. How does Homeroom respond to do-not-track signals? 

23.1 When you browse the Internet on computers or mobile devices, you can send a request to websites not to collect or track your browsing data. 

23.2 What happens to your data depends on how a website responds to the request. Homeroom does not change its behavior upon receiving a do-not-track request. Homeroom will still collect and use your browsing data to improve security, provide content, services, ads, and recommendations on their websites, and generate reporting statistics.

24. How can I contact Homeroom? 

24.1 For further information about Homeroom’s Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact Homeroom at hello@Homeroom.com.

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