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EFFECTIVE: AUGUST 2, 2021

This Privacy Notice (the “Privacy Notice”) explains our practices and governs the manner in which Brighthat Limited (“BrightHAT”) collects, uses, maintains, and discloses information collected from users (each, a “User”) of its www.mybrighthat.com website, applications, and technology platform, and any derivative or affiliated websites on which this Privacy Notice is posted (collectively, the “Site”). The Site is owned and operated by BrightHAT. Please note that this Privacy Notice covers BrightHAT’ practices regarding information collected from its Site.

The Information BrightHAT Collects and Receives
The categories of information that are collected will depend upon the nature of your interaction(s) with BrightHAT.

We collect contact information. When you submit an inquiry through the Site, we collect your name, email address, and phone number if provided, along with general information about the nature of your inquiry. When you create an account through the Site, we will also collect your username, password and other information related to providing you services through the Site.

We collect payment information from customers. If you make a purchase with us, we (or our business partner(s) who process payment transactions for us) may collect your billing or other financial information in order to process the transaction(s). Please note that we do not store payment credit or debit card numbers.

We collect Tutor and education-related information from tutors. Tutors who seek to enter into independent contractor agreements with BrightHAT are asked to provide additional personal information in support of their skills and experience, as well as bank account information to facilitate payment for their services. Tutors also have choices about the information they choose to include on their profile on the Site once under contract, such as education, work experience, skills, city or area, likes or interests, photo, etc.

We collect payment information for Tutors. If you are a freelance Tutor then we will collect bank account or other financial information in order to facilitate payments to you based upon invoices you submit through the Site and in conjunction with your signed independent contractor agreement.

We collect information you submit or otherwise provide or authorize us to collect. We collect the information you post on our Site. This includes comments, documents, videos, or photos. We also collect any other information you may provide to us or authorize us to collect, including any other identifier that permits the ability to contact you. If you communicate with BrightHAT by e-mail; post messages to forums; make telephone or cell phone calls or texts; communicate through electronic devices or other interactive devices; complete online forms, surveys, sweepstakes, or contest entries; or communicate with BrightHAT by any means, any information provided in such communication may be collected by BrightHAT.

We collect demographic information and information about your interests. We may collect information such as your gender, age, income, household or lifestyle information, and information about your interests and preferences.

We collect information about third parties that you provide to us. A User may also provide personally identifiable information about others, such as emergency contact information for notification in the event a situation requires it. If you choose to use our referral service to refer a friend to our Site, then you may provide your referral’s name and email address, as further detailed in the Refer-A-Friend section below. If you submit any personal information about another individual to us, then you are responsible for making sure that you have the authority to do so and to allow us to use their personal information in accordance with this Privacy Notice.

We collect information through surveys, testimonials, comments, reviews, and blogs. You may decide to participate in a survey, to provide a review, to provide a testimonial, to comment on a blog or social media post, etc. If you decide to participate or comment, then you may provide certain information that may include personal information. In addition, we may post customer testimonials/comments/reviews on our Site which may contain personally identifiable information; however, when that happens, we obtain the customer's consent via email or other means prior to posting the testimonial authorizing us to post their name along with their testimonial.

We collect internet and electronic network activity information, such as device and usage information. We may collect information about your browser type, language preference, referring site, subsequent site, and date/time of each visitor request. The purpose in collecting non-personally identifying information is to better understand how Users use the Site. We may collect information about your operating system, Internet Service provider information and IP addresses and other device identifiers, such as mobile device information. In addition, we may collect information about your use of our Site, unique views, originating sites, etc., including through the use of tracking technologies (See section pertaining to Tracking Technologies). A User browsing the Site without registering an account or affirmatively providing personally identifiable information to BrightHAT does so anonymously.

We collect analytics information. We use certain third-party services to assist us in analysis, auditing, research, and reporting regarding the Site. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, we use Google Analytics to help collect and analyze certain information for the purposes discussed in this Policy. You may opt out of the use of cookies by Google Analytics at https://tools.google.com/dlpage/gaoptout;

https://policies.google.com/technologies/partner-sites

How BrightHAT Uses Information

BrightHAT may use personally identifiable information collected through the Site for the following reasons:

for the specific purposes for which the information was collected;
to fulfill a contractual obligation;
to contact Users regarding BrightHAT' live-learning platform;
to communicate to Users regarding products and services offered through BrightHAT, its parent, subsidiaries, and trusted affiliates;
to maintain and improve its products, services, and sites;
to provide support;
to enhance Users’ experience with BrightHAT;
to inform Users of offerings that may be of interest;
to determine your general geographical location and provide customized and localized products and services.
to process Users’ order and registration
to process payments;
for business planning, marketing, advertising and sales purposes;
for information security purposes;
to defend its legal rights;
to efficiently maintain its business; and
to comply with applicable law.
to prevent, detect and investigate or address potentially prohibited or illegal activities

Information Sharing

We may share information that we collect about you in the following ways:

We share information with our service providers and third-party vendors. For example, we contract with third party vendors for services such as email, hosting, cloud storage, maintenance, backup and analysis, communications software, marketing, business strategy, banking, payment processing, Tutor services, background checks, etc. We also share non-personal information (such as aggregate user statistics, de-identified information, demographic information, etc.) with third parties such as advertisers, content providers, and analytics providers. They are not authorized to use or disclose your personal information save for the purpose of providing their services (which includes maintaining and improving their services)

We share information within the BrightHAT family of companies and brands. BrightHAT may disclose personally identifiable information collected from Users to its parent, subsidiaries and other related companies, trusted affiliates, independent contractors and business partners who will use the information for the purposes outlined in this Privacy Notice, as necessary to provide the services offered by or through BrightHAT and to provide the Site itself, and for the specific purposes for which the information was collected. These companies are not permitted to use your personally identifiable information in any other way. We may also share information with third parties with which we have a commercial relationship, such as an affiliate marketing agreement.

We may share information with a Tutor related to a student. In conducting the matching process between a student and a Tutor, we may share a student’s information with the Tutor who may provide or will be providing tutoring or instruction to the student so that the Tutor may evaluate the engagement and personalize and tailor the tutoring/instruction to the student. In each case, we collect such information only insofar as is necessary or appropriate to fulfill the purpose of the User’s interaction with BrightHAT.

We will share information to the extent that we are required to do so by law or to protect the company or others. BrightHAT may disclose personally identifiable information at the request of law enforcement or governmental agencies or in response to subpoenas, court orders, or other legal process, to establish, protect, or exercise BrightHAT’ legal or other rights or to defend against a legal claim or as otherwise required or allowed by law. BrightHAT may disclose personally identifiable information in order to protect the rights, property, or safety of a User or any other person. BrightHAT may disclose personally identifiable information to investigate or prevent a violation by User of any contractual or other relationship with BrightHAT or the perpetration of any illegal or harmful activity.

We may share information in connection with any business acquisition, sale, or merger, or in connection with investor relations. BrightHAT may disclose or transfer personally identifiable information collected from Users in connection with or in contemplation of a sale of its assets or business or a merger, consolidation, or other reorganization of its business provided that the receiving party commits to respect your personal information in a manner that is consistent with our Privacy Notice. BrightHAT may also disclose aggregate, anonymous data based on information collected from Users to investors and potential partners.

Users may always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain Site-related activities.

Cookies and Tracking Technologies

BrightHAT and our analytics and marketing providers use technologies such as cookies, beacons, tags, and scripts (collectively “cookies”), to analyze trends, administer the Site, track Users’ movements around the Site, and to gather demographic information about our User base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

We use cookies for tracking page view/usage (log data), estimating audience size and usage patterns, services metadata, device information, location information, saving Users’ preferences and settings information, advertising new content that relate to your interests, keeping track of advertisements and search engine results, and for authentication. Each User can control the use of cookies at the individual browser level by adjusting your browser settings. If you choose to block all cookies (including essential cookies), you may still use our Site, but your ability to use some or all features or areas of our Site may be limited.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve marketing, analytics, or site functionality.

We implement Google Analytics features that use Display Advertising information for Google Analytics Demographics and Interest Reporting.

You can opt-out of Google Analytics for Display Advertising, to prevent your data from being used by Google Analytics, by going to the Google Analytics opt-out page.

We, along with third-party vendors (including Google), use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookies) to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website. You can read more about the cookies used by Google Analytics advertising features, by going to the Google Analytics Privacy Notice page.

Behavioral Targeting

We partner with a third-party ad network to either display advertising on our Site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. You can manage your preferences for these advertising programs through the following links: Facebook, Google. Please note this would not opt you out of being served advertising. You will continue to receive generic ads.

Your Choices Regarding Your Information

Updating your account information: If you have an account, you may be able to review the information you provided to us by logging into your account page and adjusting the settings under the “Account” tab.

Email communications: If you receive an unwanted email from us, you can update your preferences by accessing the email preferences in your account settings page, or you can use the unsubscribe link found at the bottom of the email to opt out of future emails; however, please note that you will continue to receive transaction-related emails regarding products or services you have requested. You may also submit a request to us here.

Telephone/Text communications: If you receive an unwanted call or message from us, you can update or phone preferences by accessing your phone preferences in your account settings page. Regarding text messages, you may opt out of SMS by replying “STOP” to the message received.

WhatsApp Communication: If you have enabled WhatsApp messages in connection with your account or profile and no longer wish to receive them or receive any unwanted call or message from us, you can use your WhatsApp app settings to block them.

Do Not Track and other similar signals: Some internet browsers incorporate a “Do Not Track” or other similar feature; however, given that there is not a uniform way for browsers to communicate this signal, the Site does not currently support these signals.

Cookies and Internet-based Advertising: You may stop, restrict, or remove the placement of cookies on your device by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners. These may be accessed at sites such as www.aboutads.info/choices.

Deletion or Other Request: To request deletion of your information or for another request regarding your information, please complete the form request here. We will respond to your request within a reasonable timeframe, or otherwise in accordance with applicable law. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In addition to filling out the above-referenced request form, requests can be emailed to privacy@mybrighthat.com.

Data Retention

We store the information collected as described in this Privacy Notice for as long as you are a User of the Site and/or as necessary to fulfill the purpose(s) for which the information was collected, to provide services through the Site, to resolve disputes, to pursue legitimate business purposes, to enforce our agreements, to establish legal defenses, to prevent fraud, and to comply with applicable laws.

Security of Information

BrightHAT discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors, and affiliated organizations that (i) need to know that information in order to process transactions on our behalf or to provide tutoring services, and (ii) that have agreed not to disclose it to others. We take all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.

Information about each User that is maintained on BrightHAT’s systems is protected using industry standard security measures. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@mybrighthat.com. However, no security measures are perfect or impenetrable, and BrightHAT cannot guarantee that the information submitted to, maintained on, or transmitted from its systems will be completely secure. BrightHAT is not responsible for the circumvention of any privacy settings or security measures relating to the Site by any User or third parties.

Your security is a priority and we strive to provide a safe and secure environment for our customers; however, please note that we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure. If you do not feel comfortable sending your financial/credit card over the Internet, contact us and we will be happy to fill your order over the phone.

Links to 3rd Party Sites

Please note that the Site may contain links to other Sites. These linked sites may not be operated or controlled by BrightHAT. BrightHAT is not responsible for the privacy practices of these or any other Sites, and you access these Sites entirely at your own risk. BrightHAT recommends that you review the privacy practices of any other Sites that you choose to visit.

BrightHAT is based in Nigeria, but this Site is hosted in the United States of America. If User is from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. and Nigeria’s data protection laws and User is visiting, accessing, or otherwise using the Site, please note that any personally identifiable information that User provides to BrightHAT will be transferred to the United States. Any such personally identifiable information provided will be processed and stored in the United States by BrightHAT or a service provider acting on its behalf. By providing personally identifiable information to BrightHAT, User hereby specifically and expressly consents to such transfer and processing and the uses and disclosures set forth herein.

Social Media Widgets

Our Site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our Site. These Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the Privacy Notice of the company providing it.

Blogs

Anytime you post on our blog please be aware that you are posting using a third-party application, and we have no access or control over this information. To request removal of your personal information from any blog, you can either log into the third-party application and remove your comment or you can contact the appropriate third-party application. Your interaction with these features is governed by the Privacy Notice of the company providing it.

Tutor Profiles/Bios

If you are contracted as a Tutor through the Site, then the profile you create on our Site will be publicly accessible unless otherwise indicated. You may change the privacy settings of your profile and make it non-public through your account portal, or as otherwise set forth in the terms of your independent contractor agreement.

Children’s Privacy

BrightHAT products are specifically designed to function without third party access to a child’s personal information. Our Site does not collect or retain any personal information from children except as needed to facilitate tutoring for that student, who may be a minor. BrightHAT is committed to complying fully with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). This Site assures the privacy of collected information in accordance with the BrightHAT' Privacy Notice.

BrightHAT is committed to safeguarding the information each User entrusts to BrightHAT and believes that every User should know how it utilizes the information collected from each User. Other than free information and materials that do not require any registrations or identifying information, the Site is not directed at children under 13 years of age, and BrightHAT does not knowingly collect personally identifiable information from children under 13 years of age online. For purposes of using the Site as a platform to connect with tutors, Parents may supply information such as name or age of their children in order for BrightHAT to assist facilitate the connection between student and tutor. BrightHAT may store this information in a secure digital format. Parents or guardians of children under 13 years of age may review or have deleted any personal information previously provided by the child, parent, or guardian that is ultimately collected by BrightHAT, if any, to connect the child with a tutor. If you seek to review or delete such information, contact BrightHAT at the below phone number or email address indicating what you would like to have done and BrightHAT will contact you for purposes of taking the requested action, including but not limited to refusing to permit the information’s further collection or use.

Refer-A-Friend

If you choose to use our referral service to refer a friend about our Site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting the referral to visit the Site. BrightHAT stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Changes to this Policy

We may, from time to time, update this Privacy Notice to reflect changes to our information practices. If we make any material changes, then we may notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. Please review this Privacy Notice periodically. Your continued use of the Site after any such change(s) signifies your acceptance of any changes.

Legal Disclaimer

The use of our website is subject to the terms of Use stated here. By accessing this Web site you agree to abide by these terms of Use. Please read them carefully.

Contacting BrightHAT

If you have any questions or comments about this Privacy Notice, you may contact BrightHAT via any of the following methods:

Letter: BrightHAT ATTN: Legal, 7 Ayoola Drive, New Bodija, Ibadan, Nigeria

Email: info@mybrighthat.com

EFFECTIVE: AUGUST 2, 2021