Privacy Policy

Last updated April 24, 2018

SAY GLOBAL INC. Privacy Policy

Welcome to www.sayspeaking.com, the website (hereafter the “Site”) of SAY Global Inc. (hereafter “SAY”, “we”, “us” and/or “our”). This Site is operated by SAY and has been created to provide information about our company and our online services providing foreign language tutoring for Korean learners worldwide and related services (together with the Site, hereafter “the Services”) to our Service visitors (hereafter “you”, “your”, “the student”).

This Privacy Policy sets forth SAY’s policy with respect to information, including personally identifiable data about you or the student (hereafter “Personal Data”) and other information that is collected from visitors to the Site and Services. Capitalized terms that are not defined in this Privacy Policy are defined in our Terms of Use, available at http://www.sayspeaking.com/tos. By using our Service, you consent to the data practices prescribed in this statement below.

Our Policy:

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide through the Services: We collect Personal Data from you about you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services. Wherever SAY collects Personal Data we make an effort to provide a link to this Privacy Policy.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. You acknowledge and agree that if you are providing Personal Data about a minor using the Services, you have all rights necessary to do so. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of SAY and the authorized third parties referred to herein.

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

Non-Identifiable Data: When you interact with SAY through the Services, we receive and store certain non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. SAY may store such information itself or such information may be included in databases owned and maintained by SAY affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, SAY often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and SAY may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. SAY may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.

Tracking Users’ Use of SAY: We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. These services use cookies and Javascript to track number of visits, links users click on, sections users read, and analyze how users use the Site allowing us to enhance your experience when you use the Service.

For more information on how these services uses this data here are some of the services we may use: Google: www.google.com/policies/privacy/partners/, Optimizely - https://www.optimizely.com/privacy/, HotJar -https://www.hotjar.com/privacy, and Lucky Orange - http://luckyorange.com/privacy.php

Cookies: In operating the Services, we may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.

We also may use local shared objects, also known as Flash cookies, to display content based upon what you view on our site to personalize your visit. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here:
http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html#117118

Our Use of Your Personal Data and Other Information: SAY uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided.

For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. We may also use Personal Data to allow you to book and pay for tutoring sessions, catalog information about the student’s progress, send you reminders or alerts about upcoming sessions or to notify and thank an individual or school that referred you to the Service that you have signed up.

SAY and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. SAY and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

If SAY intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information: SAY is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. Further, we will never share your address, email address, phone number, or payment information with any third party. Without limiting the foregoing, there are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Tutors: SAY will share certain information with our tutors and tutor managers as necessary to provide you the Services and improve upon your experience. This information includes, but may not be limited to, your name, age, school and grade, city and state, language level and interests, content discussed in tutoring session, word list and account activity, feedback or reviews, as well as any comments or notes from previous tutors. All of our tutors are bound by confidentiality obligations and are prohibited from using such information outside of providing the Services to you.

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties: SAY like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: SAY may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of SAY, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Exclusions: SAY does not knowingly collect Personal Data from children under the age of 13. The Service and its content are not directed at children under the age of 13. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at support@sayspeaking.com.

Links to Other Web Sites: This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by SAY (hereafter “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that SAY endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Security: SAY takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. 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 Data to SAY via the Internet.

Other Terms and Conditions: Your access to and use of the Services is subject to the Terms of Service at http://www.sayspeaking.com/tos

Changes to SAY’s Privacy Policy: The Services and our business may change from time to time. As a result, at times it may be necessary for SAY to make changes to this Privacy Policy. SAY reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Modifying Personal Data: To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services. You may also update these information directly on your Dashboard Profile. Please also feel free to contact us if you have any questions about SAY’s Privacy Policy or the information practices of the Services. You may contact us as follows: support@sayspeaking.com