Learning Pool, Inc., Remote-Learner US, Inc., Remote-Learner Canada, True Office Learning, Inc. Privacy Policy

How and for what purposes we use the information collected about you

Introduction

Learning Pool, Inc. Remote-Learner US, Inc., Remote-Learner Canada, Inc., True Office Learning, Inc. (“us” “we” or “our”) takes the privacy of our users (“you” or “yours”) information very seriously. This privacy policy (“Privacy Policy”) explains:

the information we collect about you;
how that information may be used;
with whom the information may be shared;
how you may update the information you provide us;
how you may contact us; and
your choices about the information.

Please read this Privacy Policy carefully. By using or accessing the https://learningpool.com or https://www.trueofficelearning.com, as well as related websites (the “Sites”) and any services we offer via the Sites or other online services provided by us pursuant to a separately-executed services agreement (together with the Sites, the “Services”), you are agreeing to be bound by this Privacy Policy in respect of the information collected about you via the Services.

Information Collected

This Privacy Policy primarily concerns Personal Information, which deals with individuals, rather than organizations or businesses. “Personal Information” uniquely identifies an individual or can identify an individual by combining it with other data. It includes email addresses, phone numbers and other information associated with the individual. The legal name and definition of personal information differs from jurisdiction to jurisdiction. We will not use or share Personal Information other than as described in this Privacy Policy.

We collect Personal Information about you that may include your name, e-mail address, general usage metrics of the Services, your financial payment information, your profile, email communication history with us, anything you may post on the Sites and other information associated with you or your organization, as well as other information that may or may not specifically identify you. The information collected through the Services may be stored at servers, computers, or other media located in the United States.

We may obtain information about you from third-party sources, such as Google, Apple or your employer, when applicable. This information may be utilized, analyzed, and/or compared with information that we have collected from you or that you have submitted to the Services. If we obtain information from third-party sources, you agree that your sole legal remedy for any harm associated with that information is against the third-party that provided the information to us, and that you will not assert any cause of action, claim or demand against us other than requesting we delete any erroneous information.

For the avoidance of doubt, we shall be entitled to collect anonymous and/or aggregated data across its various products and services provided that no individual natural person can be identified from such data (“Aggregate Data”). The Aggregate Data will be used to analyse behaviour, trends and needs and to improve, and enhance our services and for other development, creation of new features, diagnostic and corrective purposes in connection with our services. We shall own all right, title and interest in and to the Aggregate Data and this is not considered Personal Information.

Information Collection Technology

We may use various technologies, including “cookies” “Google reCAPTCHA” and “Google Tag Manager” and web beacons to collect information, pursuant to your use of the Services, from your electronic device about your activities using the Services. We may collect and store non-personally identifying information through cookies, and third-parties to profile user activity and preferences. Technical and specification information about your device and settings may be collected when you use the Services. This information may include your Internet Protocol (“IP”) address, your browser type, operating system, access time(s), the content of previously accepted “cookies” from us, and the website address that referred you to our Services.

A cookie is data stored on your device that tracks non-personal information about you. When using our Services, we may assign your device one or more cookies that enable us to improve the quality of our Services and to personalize your experience. Cookies allow us to automatically collect information about your activity on our Services, such as the content you access while using our Services, the links you click, and other activity you conduct while using our Services. You may choose to modify your device setting to disable cookies or limit their use. If you choose to disable or limit cookies, or otherwise limit your device permissions to the Services, you may experience diminished performance from the Services and/or may be prevented from using some or all features of the Services. Our cookies generally fall into one of four categories: Essential, Functional, Analytics and Target.

Our Services may contain web beacons (also known as “clear gifs”) or similar technologies that gather non-personally identifiable information about your use of our Services. Such technology may also be contained in e-mail messages or newsletters from us that allow us to determine whether messages have been accessed. The purpose of our use of this technology is so that we may analyze the effectiveness of our marketing efforts and the quality of our Services.

Acceptable use

You are solely responsible for the content you submit to us and by doing so you agree to adhere to the following.

You may not submit any material which:

advertises or promotes goods or services;
reveals any confidential or sensitive information;
contains or links to any unlawful, defamatory, harmful, harassing or indecent material which is deliberately intended to upset other users;
encourages conduct that constitutes a criminal offence;
contains any material which you do not have permission to use (including material which is copyright or trademark protected)
contains viruses or any other components with harmful or contaminating effects on the Sites, our Services or any equipment connected to them;
impersonates others;
interferes with any other person’s use or enjoyment of the Sites or Services
uses a third party’s internet domain name, or is relayed from or through a third party’s equipment, without permission of the third party;
contains false or misleading information in the subject line or otherwise contains false or misleading content;

In addition, you may not use our Services for:

illegal activity
child sexual abuse material or any content that exploits or harms children – we wil report this to the relevant authorities
bullying behaviour, glorifying violence or celebrating the suffering or humiliation of others
generation of malware, being content that attempts to generate code that is designed to disrupt, damage, or gain unauthorized access to a computer system
activity that has high risk of physical harm, including weapons development, military and warfare, management or operation of critical infrastructure in energy, transportation, and water
activity that has high risk of economic harm, including multi-level marketing, gambling, payday lending, automated determinations of eligibility for credit, employment, educational institutions, or public assistance services
fraudulent or deceptive activity, including scams, coordinated inauthentic behaviour, plagiarism, academic dishonesty, astroturfing, such as fake grassroots support or fake review generation, disinformation, spam or pseudo-pharmaceuticals
political campaigning or lobbying, by generating high volumes of campaign materials, generating campaign materials personalized to or targeted at specific demographics, building conversational or interactive systems such as chatbots that provide information about campaigns or engage in political advocacy or lobbying, building products for political campaigning or lobbying purposes
activity that violates people’s privacy, including tracking or monitoring an individual without their consent, facial recognition of private individuals, classifying individuals based on protected characteristics, using biometrics for identification or assessment, unlawful collection or disclosure of personal identifiable information or educational, financial, or other protected records
engaging in the unauthorized practice of law, or offering tailored legal advice without a qualified person reviewing the information – our Services are not fine-tuned to provide legal advice. You should not rely on our models as a sole source of legal advice.
offering tailored financial advice without a qualified person reviewing the information – our Services are not fine-tuned to provide financial advice. You should not rely on our models as a sole source of financial advice.
telling someone that they have or do not have a certain health condition, or providing instructions on how to cure or treat a health condition – our Services are not fine-tuned to provide medical information. You should never use our models to provide diagnostic or treatment services for serious medical conditions. Our servcies should not be used to triage or manage life-threatening issues that need immediate attention.
high risk government decision-making, including law enforcement and criminal justic, migration and asylum

You must not use the Sites or Services in a manner that could damage, disable or impair any aspect of any of the site or interfere with any user’s enjoyment.

If we believe that unauthorised or improper use is being made of the Sites and/or the Services, it may at any time take such action as it deems appropriate, including without limitation, blocking or deleting content from a particular domain, mail server or IP address, or suspending or blocking your account or access rights.

Moderation

In addition. we reserve the right, at our own discretion, to moderate content that we feel is inappropriate, may cause offence or harm, or is any way threatening to users on any of our Services.

We characterise such content as follows:

CATEGORY	DESCRIPTION
hate	Content that expresses, incites, or promotes hate based on race, gender, ethnicity, religion, nationality, sexual orientation, disability status, or caste. Hateful content aimed at non-protected groups (e.g., chess players) is harrassment.
hate/threatening	Hateful content that also includes violence or serious harm towards the targeted group based on race, gender, ethnicity, religion, nationality, sexual orientation, disability status, or caste.
harassment	Content that expresses, incites, or promotes harassing language towards any target.
harassment/threatening	Harassment content that also includes violence or serious harm towards any target.
self-harm	Content that promotes, encourages, or depicts acts of self-harm, such as suicide, cutting, and eating disorders.
self-harm/intent	Content where the speaker expresses that they are engaging or intend to engage in acts of self-harm, such as suicide, cutting, and eating disorders.
self-harm/instructions	Content that encourages performing acts of self-harm, such as suicide, cutting, and eating disorders, or that gives instructions or advice on how to commit such acts.
sexual	Content meant to arouse sexual excitement, such as the description of sexual activity, or that promotes sexual services (excluding sex education and wellness), erotic chat or pornography
sexual/minors	Sexual content that includes an individual who is under 18 years old
violence	Content that depicts death, violence, or physical injury.
violence/graphic	Content that depicts death, violence, or physical injury in graphic detail.

Permissions

The following section only applies if you use one of our mobile software applications (the “Software”). The Software requires certain permissions on your mobile device in order to work as intended. You can either allow or deny the Software access to the permissions. In some cases it is necessary for you to grant the Software permissions to take full advantage of features or functionality of the Software. If you disallow some or all permissions, the Software may not function properly. Some of the permissions needed may include access to your device’s: camera; calendar; location; phone; sensor; SMS; and storage. Additional permissions may be requested as new features are added in the future.

Information Use and Sharing

We may use and share your information for any legally permissible purpose. We may match, use, and share any of the information we collect from you to any personally identifiable information we obtain through third-parties. The ways we may use or share information that we collect about you include:

providing you with use of the Sites and Services;
providing you with products or services, whether from us, or any affiliates or sponsors;
providing you with customized content and services;
providing technical or customer support;
performing research and analysis to gauge the use of the Sites and Services;
communicating with you by e-mail, postal mail, telephone, text message, and/or mobile devices about products or services that may be of interest to you from us, any affiliates, sponsors or other third-parties;
enforcing, this Privacy Policy, our other posted policies, enforce our agreements, or otherwise manage its business;
to administer the working relationship with you/your employer;
where we have another legitimate interest in doing so;
in connection with any possible sale merger or restructuring of all or any part of our business or assets; and
performing functions as otherwise described to you at the time of collection.

In order to perform certain services on your behalf, we may publish certain information that you provide. You agree that any testimonial feedback, stories, posts, interactions or other comments provided by you to us through any form of communication including but not limited to through the Sites, becomes our sole and exclusive property of and that such information may be used for any legally permissible purpose, including, but not limited to marketing and advertising our Services.

You acknowledge and agree that we may use and disclose your personal and non-personal information to public or private third-parties: (i) for inspection by law enforcement officials (including in the case of potential criminal activity); (ii) to respond to cease and desist letters, arbitration proceedings, legal actions and suits, criminal and civil subpoenas, any court orders; (iii) to enforce or apply the terms of this Privacy Policy or any other agreement between us; and (iv) to protect our, our users, and others’ rights, property, or safety whether during or after the term of your use of our Services.

If you are using our Services through your employer we may also share your information with your employer to the extent permitted under this Privacy Policy or as necessary to provide the Services, improve the Services, or to show usage.

Accept as otherwise provided in this Privacy Policy, we will not sell, rent, license, or trade your Personal Information to third party.

Unless otherwise provided in this Privacy Policy, we shall not disclose Personal Information you submit to us except (i) with affiliates, licensees, subsidiaries and successors, (ii) when we have your permission, or (iii) as necessary to:

To our affiliates as permitted by law;
To third parties who provide information technology services such as website hosting, computer systems maintenance, or data security and privacy services;
To our partners, vendors or others who help us operate the Services or assess your interest or satisfaction with the Services, our organization, or our products, provided they have contractually agreed to adhere to this Privacy Policy; or
To comply with our legal obligations, enforce our Terms and Conditions, Remote Learner Terms and Conditions-US, Remote Learner Terms and Conditions-CAD, this Privacy Policy, any other of our agreements, or otherwise to protect the rights, property or safety of our users and business partners.

Communications from Us

Unless you opt out of certain communication features, we may use your information to communicate with you, such as through e-mail, newsletters, and telephone. You may opt out and/or unsubscribe to communications at any time. See the Opt-Out Provisions and Updating Your Information section below for applicable contact information and directions.

Opt-Out Provisions and Updating Your Information

You may contact us to review, update and correct your Personal Information.

Our emails will include a link to opt out from receiving further electronic communications from us. At places on our website where you give us your Personal Information, you may opt out of receiving those communications. You may also opt out of future electronic communications by contacting us as provided below.

We may need to verify your identity before providing you with Personal Information or updating it in our system.

Children’s Policy

The Sites and Services are meant for adults and those who have reached the age of majority as defined by the laws of their domicile. The Sites and Services are not meant for individuals under the age of sixteen (16) or those defined by the laws of their domicile as minors. Nonetheless, this Privacy Policy is still designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) to the extent COPPA applies to us. Accordingly, we do not knowingly collect or retain any personal information about users under the age of information about a child under the age of 13, that information will be promptly deleted from our databased and all other media. Since we do not collect information from users who are under 13 years old, no such information is disclosed to third-parties.

External links and Third Party Privacy Policies

We cannot guarantee or verify the contents of any externally linked website. You should therefore note you click on external links at your own risk and we cannot be held liable for any damages or implications caused by visiting any external links. This Privacy Policy does not cover any third party’s use or handling of your information once it is shared. Instead, the privacy policy of the third-party will govern. We encourage you to visit the websites of those third-parties and fully read and understand their privacy policies. Some of these entities will have different privacy terms than we do and their servers may be located outside the United States.

The Services may link to other websites, including but not limited to health care provider pages, or through advertisements. We disclaim any and all responsibility for the privacy practices of third-parties that may have links to or from our Services. We encourage you to review the privacy policies/statements of every website that you visit that collects personally identifiable information.

Social media platforms

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

You are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy policy and personal details use. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage any users wishing to discuss sensitive details to contact us through primary communication channels such as telephone or email.

The Site may use social sharing buttons which help share web content directly from web pages to the social media platform in question. You are advised before using such social sharing buttons that you do so at your own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

Information Retention and Security

We may store your information from the time of initial submission, as well as automated personal information about you. However, if we obtain or collect your social security number, that information will be encrypted and securely stored.

We take reasonable security measures to protect users’ information against unauthorized access, loss, alteration, or destruction. These measures include encryption, intrusion detection, intrusion prevention, anti-malware endpoint protection and industry standard data center security measures to guard against unauthorized access to systems where we store personal information, and the usage of reputable third-party vendors. Despite these reasonable measures, we cannot guarantee our security measures are impenetrable. Therefore, although we take reasonable steps to secure your information, we cannot and do not promise or warrant that your information will always remain secure.

If you believe there has been any breach of security such as the disclosure, theft or unauthorised use of your ID, you must notify us immediately by emailing [email protected]. If we reasonably believe that your ID is being used in any way which is not permitted by this Privacy Policy, we reserve the right to suspend access rights immediately on giving notice to you and to block access from your ID until the issue has been resolved.

If we have reason to believe that there is likely to be a breach of security or misuse of the Sites or Services, we may also require you to change your password.

California Privacy Rights

We will not share any personal information about you with other companies if prohibited by applicable California law or to the extent your prior consent to share is required by applicable California law.

If you are a California resident, you may have certain rights with respect to your Personal Information including the following rights:

the right to know, by way of our Privacy Policy and any specific inquiries you direct to us, where personal information we have about you comes from, what we use that information for, whether it is being disclosed or sole, and to whom it is being disclosed or sold;
the right to “opt-out” of our sale of your personal information to any third parties;
the right, with some exceptions, to have your personal information deleted from our possession or control; and
the right to receive equal service and pricing from us even if you exercise any of your privacy rights.

To make such a request, or if you have any questions or concerns about your California privacy rights, our Privacy Policy or our use of your personal information, please contact us at as provided below.

EU Resident Rights under the GDPR

These disclosures apply only to our processing of Personal Information within the scope of the General Data Protection Regulation (“GDPR”) from one or more of the European Union Member States plus Iceland, Lichtenstein and Norway (together known as the “European Economic Area” or “EEA”).

The GDPR went into effect on May 25, 2018. As a resident of the EU or EEA, you have certain rights with respect to the processing of your personal data, including:

Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at [email protected] if you wish to make a request.

Contact Us:

Learning Pool Inc.

Industrious NYC,

1411 Broadway,

16th Floor,

New York

NY 10018

On any email or postal letter you send, please include “Privacy” in the subject line.

Changes to this privacy policy

This Privacy Policy may be updated from time to time. We reserve the right to modify the Policy at any time without notice, so please review the Privacy Policy frequently. When changes are made to this Privacy Policy, we will revise the “last updated” date at the bottom of this Privacy Policy. Your continued use of our Sites or Services after we have posted any policy changes indicates your agreement to the changes unless you notify us otherwise.

If you wish to retain a copy of this Privacy Policy, you should print a copy or save a copy for your records.

Last Updated: August 2023