Effective Date: January 1, 2021
Introduction
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.
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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.
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We use the latest security industry best practices to protect you.
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We are transparent about our practices and will notify you if things change.
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We are compliant with FERPA, COPPA, GDPR, MFIPPA, and the Australian Privacy Act.
This Privacy Policy governs the use of data collected by our websites at thetomo.org. By using Tomodachi, you agree to this Privacy Policy.
Parental Consent
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:
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identifying information such as your name, address, telephone number, and email address;
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geographic or location data, which may be precise or imprecise;
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content of your communications via the services;
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information relating to the performance of the services you experience; and
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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:
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to appropriately respond to your communications;
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to provide you with a personalized experience when using our services;
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to provide targeted advertising to you (presuming you’ve already agreed to receive promotional messages or emails from us);
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to contact you about new and enhanced informational services (again, presuming you’ve already agreed to receive promotional messages or emails from us);
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for internal statistical, marketing or operational purposes, including measuring and understanding demographics, user interest, and other trends among our users; and
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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:
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Service providers. We will provide your personal information to third parties who provide services to help us with our business activities and the provision of the services. For example, we may use third-party service providers to help us analyze usage of our services, provide personalized advertising, track the effectiveness of our marketing campaigns and communications, assist with the prevention and investigation of potentially illegal acts or violations of our Terms of Use or this Privacy Policy, collect and process error and crash reports, and host web servers and store data. These third parties are authorized to use your personal information only as necessary to provide these services to us.
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Business reorganization. We may also disclose or transfer your personal information to an affiliate or a third party in the event of a sale, merger, bankruptcy, sale of assets or reorganization of our company. Your consent to our Terms of Use and this Privacy Policy is deemed transferable to the new entity. We will notify you if a different company will receive your information.
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Legal disclosure. Subject to applicable laws in your jurisdiction, we may also disclose personal information about you to others as we believe to be necessary or appropriate: (a) under applicable law or regulation, including laws or regulations outside your country of residence, (b) to comply with legal process, respond to legal claims, (c) to respond to requests from public authorities and law enforcement officials, including officials outside your country of residence, (d) to assist or support theft investigations involving our services or property, (e) to enforce our Terms of Use and this Privacy Policy, (f) to protect our operations or those of any of our affiliates, (g) to protect the rights, privacy, safety or property of People’s, its affiliates, you and others, or (h) to permit us to pursue available remedies or limit the damages that we may sustain.
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International transfer and storage. Your information may cross international borders in order to facilitate the services. By using the services, you consent to the use of your Information to countries outside your country of residence, which may have different data-protection rules than in your country and therefore may be available to government authorities under lawful orders and laws applicable there. However, our practices regarding your information will at all times continue to be governed by this Privacy Policy.
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.
How Does Tomodachi Use Cookies?
Cookies are small text files that we transfer to your web browser that allow us to identify your web browser and store information about your use of Tomodachi. We may use cookies, web beacons, or other similar tools in our services to help personalize your experience. We may also engage one or more third-party service providers to issue online advertisements on our behalf. We may use, or authorize the use of these or other similar technologies to collect information about your visits to the services, and we may use that information to send you targeted advertisements.
If you do not wish to accept cookies, you have the option to block or disable them. Your computer or device lets you clear all stored cookies, should you wish to do so. However, please be aware that you may be unable to access certain parts of the services if you block or disable our cookies.
Updates and Changes
We reserve the right to update this Privacy Policy from time to time by posting changes to the website. Your continued use of Tomodachi constitutes consent to these changes.
Withdrawing Consent
You may withdraw your consent for our collection, use, and disclosure of your personal information at any time. If you wish to withdraw your consent, please contact us. This will affect your ability to access or use the services. Your access to the services will be revoked if you withdraw consent, and if you continue to use the services thereafter, your consent to this Privacy Policy is deemed unconditionally renewed.
Contact
If you have any questions about this Privacy Policy, please contact us at info@thetomo.org.