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Privacy Policy

Last Updated September 19, 2023

 

 

This Privacy Notice (“Notice”) describes how Kingford Academy (registered name as Monwado LLC) (“Kingford Academy,” “we,” “us,” “our”) an online marketplace platform for education and engagement, collects, uses, and otherwise processes your personal information. Below, we provide more details about our practices, including the types of personal information, individuals, activities, and third parties.

This Notice applies to the information that we process including what we do with personal information that is provided to us by organizations we work with, such as schools, non-profit organizations, or employers. However, we can only tell you what we do with the personal information, not what any other organization does unless they are our vendor, hired to process data according to our instructions. In particular, when a Learner is enrolled in another organization’s program, the organization is directly communicating with Learners and their Parents about the program; the other organization’s privacy notice will apply and you should ask them how they process personal information. 

Please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy notices of other sites that may collect your personal information.

We may change this Notice at any time and will include the last date it was updated. If necessary or there are material changes, we will provide notice or obtain consent regarding such changes if required by law. 

Please review the sections below and if you have any questions, please do not hesitate to contact us at support@kingfordacademy.com.

 

Key Terms

We use some key terms in our Notice that you should know as you read the information.

  • Customers include Learners and their Parents, Teachers, and Partners

    • Learners are the minors (18 years and younger) who participate in Kingford Academy activities

    • Parents are the parents or legal guardians of the Learners

    • Teachers are the independent contractors - either individuals or organizations - who offer, classes through Kingford Academy’s platform

    • Partners are companies (third parties) that we work with, such as schools, technology vendors, employers, or non-profit organizations, and who are not “teachers”

  • Services means the Classes or Activities or other engagement by Customers with Kingford Academy

    • Classes means the courses developed / taught by Teachers, whether individuals or organizations

    • Activities means the groups, challenges, and other types of engagement through or with Kingford Academy in which any Customers may participate, whether paid or free

  • Personal Information/Data means information linked to an identified (or identifiable) person 

  • Process means any activity with personal information, e.g., collecting, using, sharing, storing, etc.

 

Your Personal Information

Website Visitors and General Consumers (anyone) 

We collect information through technology for website visitors who do not engage with us directly. If you interact on our website, we will track your activities online, but we do not know who you are. 

However, if you submit a form with your contact information, we will engage with you as requested and may follow up with you to further build a relationship, generally through Communications and Marketing. You can opt out of marketing communications at any time. 

Anyone can engage with us in certain areas: Communications, Social Media and Marketing. Each is addressed below in more detail. 

How do we collect this information? This information is typically provided by you voluntarily. Where it is not voluntary, it may be in the realm of employment or legal proceedings and follow the requirements of applicable law. In addition, we buy services or information that help us learn more about you and communicate with you.

Why do we collect this information? We respond or initiate communications in provision of the Activities or in response to a request. This is based on the requirement to provide you services or our legitimate interest to grow our business and understand our Customers and their needs better. Our legitimate interest in this relates to sending you the request, in which you may choose to respond or not and can choose to ask us not to contact you for those purposes. Given this, our legitimate interest is not outweighed by the risk to you. 

Communication 

When you communicate with us, regardless of the channel, we keep records of communications and act on them as appropriate, whether email, messaging, or other forms of communication. Communications may be managed by various departments and/or third parties, including Trust & Safety or Legal. We may also communicate with you to better understand our market, and ask you to participate in study groups, surveys, video interviews, etc. We will provide more information to you at the time.

Social Media 

We may interact with you using social media in a variety of ways. We may “follow” you or ask you to “follow” us. We may create groups on social media for interaction. We may ask for your social media handles or tags to use in advertising. We may copy your posts or statements and follow up internally or with you.

Marketing 

We will use your contact information to communicate with you, unless you instruct otherwise. We do not collect Learner information for marketing purposes. We may obtain information from third parties, such as matching your email address to a publicly available physical address and sending physical marketing materials, like postcards. You can request that your email or other information in your profile not be used for marketing purposes. If you opt out of marketing emails, we will continue to send emails related to Classes or Activities and respond to any requests from you. Please contact support@kingfordacademy.com. for questions.

Individuals with Third Parties

If you work for (or are with) a Partner, vendor, or other third party, we engage with you as required for the relationship to build, maintain, and terminate. We will only process your business-related information in furtherance of our relationship and engagement in the potential or actual relationship, such as payments, contracts, and via technology. You may also engage with us as a member of the general public as described above or as a Customer described below.

Customers (Teachers, Parents, Learners, and Partners)

The personal information we process can be grouped into three main categories: information you (or your learner) provide to us, information we get from third parties about you, and information we get from cookies and trackers. We provide information on inferring data and combining data.

  1. Information you provide to us

  2. Information we get through third parties (such as partners or via social media); and 

  3. Information we get through technology, including device info, cookies and trackers.

  4. Inferred and Combined data

1. Customers - information you provide to us 

For engaging with us, you provide us information directly for your Account, Services, and Finance. More detail is provided below for each one of these, but here we explain how and why we process this information. 

How do we collect this information? If you engage with us directly, we collect this information from you or from linked accounts (like Google or Facebook log-ins) that you choose to share the data with us. You also volunteer information when you complete parts of your profile. You can choose not to provide this information. If you come to us through a partner, some of the data comes from them, but some is provided by you when you complete the registration. If you are a Learner, your Parent may provide your information. When engaged with classes or activities, participants may be requested to submit some information to complete the assignment and some information is volunteered through your engagement, like comments or feedback.

Why do we collect this information? We collect this data to add you to our platform and let you engage with us - generally at your request or consent, which you may revoke at any time. Revoking consent may end your classes, activities, or account, depending on your request. Some information is provided for learner safety, such as video evidence that the person in the Activity other than the Educator is a child. If you refuse to provide a video, you may be refused to join Activities. You can participate without providing any voluntary information, but you must provide required information. We may also use information provided to us to prevent fraud. In general, we use your information to provide the Services, customer support, and to improve our platform and Services.

1.1 Account Information

When you join Kingford Academy, we ask for your name or publicly posted name from a linked account (such as Facebook, Google or Apple), email address, phone number, and postal address. We collect information about the Activities you can or wish to be involved with (as an Educator or as a Parent or Learner) and keep a history of your Activities. You may choose to provide additional information in your profile, such as age, gender, pronouns, title, and profile photo. To activate your account and participate in Activities, Learners will submit a video recording for verification, as well as all live classes are recorded and cameras required to be on for at least a portion of the Activity for the safety of all Learners. Where necessary, an account may require a contract to be in place.

1.2 Services

We collect information about the Classes, Activities, or other Services for which you or a Learner engages in, comments and communications, instructions, information you share such as drawings or photos, class or Teacher reviews, video and audio, and the history of activity in and with Kingford Academy. This may include uploaded items, such as photos or drawings. If information is uploaded to Kingford Academy, it may contain metadata such as who created or last modified it, the date created or modified, location, and such. You can generally check metadata by clicking on the properties for that item. We do not require any metadata on submitted items and we do not purposefully use any. We do not support or encourage communication outside our platform, except where required and specifically approved by the course, e.g., gaming. At times, we may want to test if certain parts of the website or Services work better than others and if so, may present one version to some group (of Customers, general consumers, etc.) and one to another.  There is no substantive difference between the options, mainly just presentation, such as testing whether more people like the “load more” option or the page clicking. We do this to better determine how to design our site for engagement.

1.3 Finances

For purchases, we collect name, credit card or other payment information, billing address, and information about the Services purchased. For payments to you, we collect your financial account information if necessary, payment details, and information about our payments, such as the reason or history. We also use financial information to detect or prevent fraud.

1.4 Sensitive Data 

“Sensitive data” has different meanings depending on location. Where possible, we apply heightened protection to sensitive data. In some places, information from a child may be considered sensitive information itself. You or a Learner may voluntarily provide sensitive information, such as health or disability information included in forms, messages, or with a complaint or concern. Learners may also be enrolled in special classes offered for Learners with disabilities and Teachers may volunteer their disabilities within a class. Teachers and Learners are otherwise not allowed to have discussions that may elicit or result in sharing of sensitive information, and where they do learn sensitive information, they are not permitted to share that outside Kingford Academy or use it in an inappropriate way.

  • Fraud. If we suspect that a Learner is over the age of 18 or misrepresenting their identity, for the safety of other Learners, we may request proof of appropriate age or identity, such as a video clip or the Learner’s birth certificate, passport, or driver’s license. This documentation may contain sensitive data such as full date of birth, place of birth, and government ID numbers. We only retain the information necessary, such as date of birth.

  • Background Check Information. Teachers and potential employees must provide information as part of our background check process, including criminal history information, professional education and qualifications, work history, references, and teaching abilities. We provide separate notices and consent forms before performing background checks. 

2. Information we get through Third Parties

We may get information on you from Customers, Partners, third parties or vendors on Customers or potential Customers. This may include us getting the information directly or it may be getting your information from Partners. More detail is provided below for each one of these, but here we explain how and why we process this information. 

How? We get information from third parties either by purchasing or leasing it, indirectly through our own vendors, or by engaging with you through third parties, like social media (see Social Media above). Also, our current Customers may share information in our referral program. We do not buy or lease information from third parties on Learners.

Why? In most cases, we obtain or purchase data so we can grow our business - so this is in our legitimate interests as a business to do so. We may use this data to report suspicious activity to a local agency. If so, this is either for addressing fraud or for the safety of Learners. 

Information from Partners. Kingford Academy partners with other organizations, such as schools, non-profits, and employers to provide services. In general, these Partners would provide your information to us for you to participate in Classes or Activities in which they have control (such as schools) or where they are offering the Services to you as a joint effort. Partners will likely provide you with specific information when the relationship is set up, especially if they have control over the Classes or Activities. If so, you need to look at their privacy notice for how they handle your information. 

We also partner with technology companies to jointly provide some services. In some cases, you need to create an account with the partner to use their services and when you link your account there with your account with us, they may provide information to us.

Information from Vendors. At times, we may purchase (or lease) data from third parties for certain reasons. We don’t know how these third parties get your data, but it is generally through advertising services or other companies you have used who are able to share your information. We do not sell that information, but we may share it with our vendors, such as if we buy a mailing list of parents in a certain area, we will share those addresses with a vendor who may print and mail the postcards. The data we get may be just on a group of people where we provide characteristics we want or we may provide the names (not on Learners) to get more information on them, such as addresses for marketing materials or for reporting an event to the local agencies.

Information from other third parties. At times, you may decide to login to our services using a linked account, such as Facebook or Google. We make sure that you are able to do this, but it does mean you may be providing us more information about you. You should check the privacy notices of these providers to see what they share with us. We may also get information through third parties if you use them in Classes or Activities. We try to control the use of third party tools, but we are not perfect.

3. Information we get through Technology

Some data we get through technology, such as cookies and trackers on the website. We do not knowingly track children. More detail is provided below for each one of these, but here we explain how and why we process this information. 

How do we collect this information?  This data is collected through technology. This means simply by coming to our website or using our app, you are providing certain information automatically. Some of this you can opt out through our Cookies Page or through your computer or browser settings, but others are necessary. 

Why do we collect this information? More details are below, but some data is necessary for the operations of the website and app and some are optional. Optional reasons include analytics, preferences as discussed above about testing certain features or preferences on our site, assessing user behavior and tech problems, along with other useful information. Unless it is necessary for the website or app to work, our reasons are linked to our legitimate interests in having this information that we do not believe impact your rights and freedoms. This information also helps us personalize your experience with us. It also helps us detect, investigate fraud and violations of our policies.

Technical, Device, and Usage Data: This is information that we automatically collect about your device and connection when you engage with Kingford Academy and it includes your IP address, device identifiers such as cookie identifiers and mobile device identifiers, operating system type, and the type of browser. This may include data about your usage (such as login times, search terms, items you click on, error messages, and pages you viewed) and location data. We do not collect data from third-party ad trackers on Learners.

4. Inferred and Combined Data

We provided information on how and why we collect and process your information and provided a lot of information about the sources of information and the purposes for which we use your information. However, you need to know that using your information is not always so straightforward, we infer information about you and we combine data to have a more complete understanding of you. 

Inferred Data: We may infer new information from other data we collect to generate information about your likely interests. For example, we infer the class subjects your family may be interested in from searches you may perform. We may also infer your general geographic location (such as city, state, and country) based on your IP address. 

Combined Data: We may obtain information from you from sources other than you, such as through partners, employers, third parties, or social media. For example, you may have accounts through your school or employer, and also directly. Where possible, we combine these sources to have one extensive view of individuals engaged with Kingford Academy. 

As we explained in the sections above, we may use any of the above categories of your personal data to:

  • Provide services to Customers, Partners, third parties, and employees;

  • Perform our business operations;

  • Manage our relationship with Teachers, Parents, and other individuals.

Sharing Your Data

We may disclose your personal data to the following categories of third parties:

  • Teachers: When Parents sign up for Services, they agree that Teachers may receive certain personal data about the Parents and their Learners including classes they have taken and requests or needs. Teachers are not our employees or agents, and do not process personal data on our behalf, but we do have requirements they must agree to follow on what they can do with personal data. Please note that in some cases, classes are taught by a “Teacher” that is actually an organization, group, or team of instructors. In such cases, class recordings may be accessed by the entire organization, and access would not necessarily be limited to a single individual Educator. Teachers may also need to engage others to assist.

  • Other Customers: Members of a class or activity will be able to see, hear, and read the interactions with the other members, unless a Learner private messages a Teacher. This may include other Parents, Learners, and other individuals any member of the activity or class requires in order to participate, such as an interpreter. However, no one should have other individuals involved in class that should not be there for a legitimate and pre-approved purpose. Kingford Academy prohibits non-approved people on our site engaging with Learners or other Customers.

  • Teachers using third-party sites or tools: We request that Teachers only share or use tools /third party sites that are COPPA-compliant. However, at times, Teachers prefer to use tools or sites that have not been reviewed by our team. Parents should review what sites or tools that Teachers list for specific Classes. Parents should review those sites and tools and either agree or let us or the Teacher know you disagree. Parents should check email registrations carefully and review your Learner’s Activity description or listing.

When we send you the COPPA Notice / Children's Privacy Notice for your consent, you are also consenting to the pre-approved third-party sites and tools. We will keep an updated list of these sites and tools here. We review requests for third-party sites and tools on a quarterly basis and determine if they are approved or prohibited. At any time, you are able to decline to use these sites or tools. It may have an impact on the Classes or Activities, but you are not required to use them if you disagree with them.

  • Partners: Where we work with organizations (schools, employers, non-profits, tech companies, etc.) that provide opportunities or funding to you for Services, we will share information back to them about Learner engagement. As mentioned above, you will be aware of these engagements as generally, that is how you came to Kingford Academy or used their codes / vouchers to pay for Services or you specifically connected your account with them to us.

  • Vendors/Service Providers: We engage third-party service providers to perform certain activities on our behalf, such as hosting (AWS), communications (e.g., Google, Intercom), marketing (e.g., Postmark), analytics, payment processing (e.g., Swipe, Paypal, Afterpay), video hosting (Zoom), and website maintenance. This is not a complete list, but a sample of some third parties we use.

  • Business Transactions: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred to a successor or affiliate alone or as part of that transaction along with other assets. This may occur before the transaction is complete as part of the transition or evaluation, although where possible, we will ensure the other entity honors the privacy protections.

  • Legal Requirements: We may disclose your personal data if required to do so by law or when we believe that such action is necessary to (i) comply with a legal obligation or a request from someone with legal authority to do so, (ii) protect and defend the rights or property of us or those of Customers or Partners, (iii) operate and maintain appropriate security, including to prevent or stop an attack on our computer systems or networks, (iv) to protect the personal safety of Customers or the public, or (v) protect against legal liability. Teachers are required to report to us any suspected case of child abuse or neglect they become aware of during their work with Learners. Teachers and Partners may also be required to report suspected abuse or neglect to local authorities, and we expect all Teachers and Partners to comply with their individual reporting responsibilities. We may also report instances of suspected abuse or neglect.

  • Third-Party Analytics and Advertising Companies: We allow third-party analytics and advertising vendors to collect personal information, including the Technical Data described above, data about your usage, and inferences about you based on such data. Except for data collected from Learners in Learner Space, these third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. We do not sell your data for money, but we may receive services or a discount in exchange for some data collected online (not Learner data).

  • Information Disclosures Requested by You: You may transmit information to third parties or request us to do so, including the general public. For example, you may voluntarily: (i) message others using Kingford Academy or our team; (ii) upload personal data to your user profile which is accessible to other users; (iii) disclose information about yourself to Teacher(s) and other participants in your Classes or Activities; and (iv) participate in discussion boards, social media, and public forums that may also be available to the general public. We expect everyone to respect the privacy of others and follow our requirements on posting and disclosing activities, such as disclosing private material, communications or information, or disclosing other personal data about others that may cause harm, embarrassment, or conflict. Please also see our Terms of Service.

Please note that Classes and Activities may include references or links to or suggestions to engage with third parties whose privacy practices differ from ours. Teachers may also suggest third-party resources for Parents and Learners. If you provide personal data to any of those third parties, or instruct us to disclose personal data to them, that data is governed by their privacy notices.

Your Rights and How to Manage or Delete Your Personal Information

  • Where permitted under applicable law, you have the right to request access to your Personal Information, delete, change or correct your Personal Information collected by Kingford Academy.

  • To exercise your rights mentioned above or if you are Parent/Guardian and want to correct, edit, update or delete information about your child, please contact us at support@kingfordacademy.com. If you are a Parent/Guardian, your account deletion may impact multiple Learners and if you do not specify a specific Learner, all will be deleted. Once deleted, you will not be able to reinstate your activity, class, or other history, including interactions with teachers or payment. Please note that as part of your request, we may require additional information and documents, including Personal Information, in order to authenticate and validate your identity and to process your request. Such additional information will be then retained by us for legal purposes (i.e., as proof of the identity of the person submitting the request).

Children’s Privacy

Some of the features on our websites or in our applications may be blocked or provided in a limited form to restrict the collection or sharing of data from children (typically those under 13 or the age indicated by law) or to prevent them interacting with adults. For more information, please also see our Children’s Privacy Notice and our Learner’s Privacy Guide.

Contact Us

Please contact us if you have any comments or questions about this Notice or our information processing practices by emailing support@kingfordacademy.com or mailing:

Monwado LLC

1320 Central Park Boulevard, Suite 200

Fredericksburg, Virginia 22401

United States of America

Phone: +1 (650) 519-7722

 

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