Effective Date: January 1, 2021
Tomodachi’s mission is to provide services that enable schools, teachers, and students to safely connect with each other and exchange educational ideas. We are committed to empower the people in our community to express themselves and share content that is important to them.
Protecting your privacy is fundamental to our mission and business. The following summarize our promises to you.
We will not sell your personal data or share information that directly identifies you (such as your name, email address, or other contact information) with advertisers.
We use the latest security industry best practices to protect you.
We are transparent about our practices and will notify you if things change.
We are compliant with FERPA, COPPA, GDPR, MFIPPA, and the Australian Privacy Act.
We are committed to protecting the privacy of children. We require that teachers or schools get parental consent before using Tomodachi with children who are under the age when they can grant consent on their own. This age may vary based on where you live. For example, in the US that age is younger than 13. You should check your local laws to determine the relevant age in your country. If you are aware Tomodachi is collecting information from a student without parental consent, please contact us immediately and we will delete the data.
What Information Does Tomodachi Collect?
We collect personal information from you as follows:
Using our services. We collect personal information from you and any devices you use when you engage with us or third parties in connection with any part of our services. Such information may include:
identifying information such as your name, address, telephone number, and email address;
geographic or location data, which may be precise or imprecise;
content of your communications via the services;
information relating to the performance of the services you experience; and
information you provide in any communications with us.
Automatic collection. When you use our services, we may automatically gather information about how you’re using them, as well as information about your devices, such as your Internet protocol (IP) address, device ID, physical location, browser and operating system type, resolution of your screen, language settings in your browser, referring URLs, and other technical information. This information is necessary for providing personalized and location-based content and services, as well as for analyzing web traffic, troubleshooting problems, preventing fraud, and improving services.
Third-party data. We may obtain data from third parties. We protect that data according to the practices described in this policy, plus any additional restrictions imposed by the source of the data and applicable laws. These third-party data sources vary over time, but may include data brokers from which we may purchase demographic data to supplement the data we collect, service providers that help us determine a location based on your IP address in order to customize certain offerings to your location, and any partners with whom we offer co-branded services or engage in joint marketing activities.
How Does Tomodachi Use This Information?
We use this information to provide our services to you and to improve our services in order to better serve you, such as:
to appropriately respond to your communications;
to provide you with a personalized experience when using our services;
to provide targeted advertising to you (presuming you’ve already agreed to receive promotional messages or emails from us);
to contact you about new and enhanced informational services (again, presuming you’ve already agreed to receive promotional messages or emails from us);
for internal statistical, marketing or operational purposes, including measuring and understanding demographics, user interest, and other trends among our users; and
to detect, prevent, mitigate, and investigate fraudulent or illegal activities or security issues.
Will Tomodachi Share Your Information?
We do not disclose, trade, rent, sell or otherwise transfer your personal information, except for in the following limited circumstances:
How Does Tomodachi Keep Your Data Safe?
We take steps to ensure that your personal information is only accessed by those employees whose job requires it. We maintain reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of personal information in our custody. Tomodachi follows generally accepted industry standards to protect the personal information submitted to us. In the event of a security breach, we will notify affected account holders within the amount of time required by law so that you can take steps to keep your data safe.
How To View or Update Your Personal Information?
You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You can update the information associated with your Tomodachi account directly by logging into your account and viewing the Account Settings tab, or you can email us at the contact information set out below. We will request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
How To Delete Your Personal Information?
If you would like to delete your account or any content submitted to Tomodachi, please email us at the contact information set out below. If you request that your account or any content submitted to Tomodachi be deleted, we may still retain information for up to 60 days to provide customer support and prevent accidental deletion. We are not responsible for any liability or loss you experience as a result of our disposal of personal information.
Tomodachi may still retain personal information as necessary to provide for other essential purposes such as complying with our legal obligations or resolving disputes. For example, if a valid request to inspect student education records has been made, we are required by FERPA to retain those records. We have personal information retention processes designed to keep our customers’ personal information for no longer than necessary for the purposes stated above.
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Updates and Changes