SORA SCHOOLS PRIVACY POLICY

EFFECTIVE DATE: NOVEMBER 1, 2021

  1. PURPOSE OF POLICY

Thank you for joining Sora Schools’ growing community! We are committed to protecting your privacy as you visit and use our website and any other related services provided by us (collectively, the “Service”). We understand how important privacy is to you, and we are committed to creating a safe and secure environment for all of our users. 

We created this Privacy Policy (the “Policy”) to give you confidence as you use our Service. This Policy covers how we collect, use, store, and share your information when you use our Service. The provisions of our Terms of Service, available at ttps://soraschools.com/terms-of-service and as may be updated from time to time (the “Terms”), apply to this Policy as well. All references in these Terms to “we”, “us”, “our”, “Sora,” “School” or “Sora Schools” refer to Sora Schools, Inc. All references to “you”, “your”, or “user” refers to all persons who use or access the Service, including each student or prospective student of Sora (“Student”) and such Student’s parent(s) or legal guardian(s) (referred to as “Parent,” which term includes the singular or plural, as applicable). All capitalized terms not elsewhere defined in this Policy shall have the same meaning ascribed to them in the Terms. Do not hesitate to contact us at privacy@soraschools.com if you have any questions or want to discuss this Policy. 

This Policy also describes our practices related to information of individuals with whom we communicate for marketing or promotional purposes but who may not otherwise be users of the Service (the “Marketing Recipients”). By clicking the applicable button or checkbox to indicate your acceptance to this Policy and our Terms, or otherwise by using the Service, or by agreeing to this Policy as a Marketing Recipient, you consent to the privacy practices described in this Policy and agree that you are at least 13 years old.

2. PRIVACY OF CHILDREN UNDER 13 YEARS OF AGE

Our Service is currently designed for use by students. We understand that Student users who are under 13 years of age (“Students Under 13”) require special privacy protection and safeguards under the Children’s Online Privacy Protection Act (“COPPA”).

Before we have obtained required consents under COPPA, we do not allow Students Under 13 to provide any personal information, such as first and last name, address, email address, or telephone number information. Such personal information must be provided by the Parent and will be available only to Sora staff, and we will use the information only for purposes of providing the Service. We will never otherwise share or use such information without prior consent from the Parent.

Prior to Student Enrollment with Sora.

In the event that we wish to collect personal information from a Student Under 13 prior to the time such Student is enrolled with Sora, we will first obtain a Parent’s verifiable consent by email, under a method known as “email plus.” In compliance with this email plus consent method, in a direct privacy notice to the Parent, we will explain what information we are collecting (Student’s first and last name, email address, phone number, state/region, and grade level), how we plan to use it, how the Parent can provide consent, and how the Parent can revoke consent. We will also provide a link to this Privacy Policy. If we do not receive consent from the Parent within a reasonable time, we will delete the Parent’s contact information and any other information collected from such Student Under 13 in connection with that activity. If the Parent consents, we will confirm this consent with a follow-up email.

Upon Student Enrollment with Sora.

Upon a Student’s enrollment with Sora, the Parent must provide a signed enrollment agreement (“Enrollment Agreement”). The Enrollment Agreement includes a COPPA Parental Consent Form that the Parent must fill out, sign, and return along with the Enrollment Agreement for enrollment of a Student Under 13.

3. INFORMATION WE COLLECT AND HOW WE USE IT 

Information You Voluntarily Provide Us

You will not be required to provide any personally identifiable information to browse our website. However, if you would like to contact our admissions team via our website, register for and/or attend a virtual open house, submit an application for Student enrollment in the programs offered by Sora, confirm a Student’s enrollment with Sora or otherwise use the Service, after providing any applicable consents as described above, you will be required to provide us with various information that, on its own or in combination with other information, can be used to identify you as an individual (“Personal Data”). We will collect information you provide to us voluntarily as part of the application and enrollment process or that you subsequently provide through your use of the Service. Such information includes, without limitation:

  • First and last name (for Student and Parent);
  • Physical and/or mailing address (for Student and Parent);
  • Email address (for Student and Parent);
  • Phone number (for Student and Parent);
  • Age and school grade level (for Student);
  • Social security number (for Student);
  • Financial information, including, but not limited to, credit or debit card numbers or bank account information (for Parent);
  • Health and medical information (for Student); and
  • Educational transcripts (for Student). 

We also may collect and store communications that occur through the Service or outside of the Service between you and Sora. 

Further, now or in the future, we may allow you to provide us with access to additional information and data through integrations with third-party goods and services.

The various categories of information in this subsection is, or may be, considered personally identifiable information, and is used for the purpose of providing you with the Service’s functionality. While all of the information described here may not be required to use the Service, some aspects of the Service may not be available if you choose not to provide us with such information. 

Personal Data We Collect from Marketing Recipients

In addition to the Personal Data we collect from users of the Service, we collect Personal Data from Marketing Recipients who are interested in learning more about our products and services. This Personal Data consists of basic contact information such as the Marketing Recipient’s email address. This Personal Data is collected by us when Marketing Recipients sign up for commercial emails from us via online sign-up forms, and through other means, including the Facebook platform. For Marketing Recipients who are not otherwise users of the Service, we only use your Personal Data to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with that are related to the Service. If you no longer wish to receive marketing-related emails from us, you may opt out at any time via the unsubscribe link included in such emails. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with the Service, if applicable.

Information Collected Automatically As You Use The Service.

In addition to the information that you provide to us voluntarily, we collect information automatically through the Service, such as how you use and interact with the Service, data on activities that you pursue through the Service, and other similar activities.

We may also automatically collect your IP address and geo-location while you are using the Service through your device. You may be able to limit any such collection in the settings on your device. As with the voluntarily provided information described above, some aspects of the Service may not be available if you choose not to provide us with such information and Personal Data as applicable.

Additionally, if you participate in a virtual open house, we may use videoconferencing software. As such, your name, image and/or voice may be accessible to other participants at such time.

The information described above is used to provide you with the Service, to better understand our users and how they use the Service, and to improve the Service.

Cookies.

After you have interacted with the Service on our website, we use cookies to remember you as a user of the Service and to streamline the functionality of the Service. Cookies set by us are called “first-party cookies”. Cookies set by other parties are called “third-party cookies”.

Sora uses first-party cookies that are only used to track your activity on the Service, and not on third-party sites or services.

In addition, Sora uses the following cookies:

  • Google Analytics Cookies – Google Analytics is used by Sora for aggregate data to understand trends and usage patterns so as to improve the Service. These cookies do not collect personally identifiable information on our behalf, although Google may know who you are for their own purposes. Google Analytics uses only first-party cookies for data analysis. Information pertaining to privacy through the use of Google Analytics can be found at http://www.google.com/policies/privacy/partners/.
  • Stripe Cookies – Sora uses Stripe, Inc. (“Stripe”) cookies for purposes of integration into Stripe’s billing and payment services. Your personal financial information, including your credit card information, is provided directly to Stripe, whose use of your personal information is governed by their privacy policy (the “Stripe Privacy Policy), which may be viewed at https://stripe.com/privacy. Additional information on Stripe cookies can be found here: https://stripe.com/cookies-policy/legal.

Other Anonymous Data We Collect

When you use and visit the Service, we may also use web beacons (tracking pixels) or third-party services, such as Google Analytics, as described above, and Hubspot, all of which may use cookies to collect or track generic, anonymous information that does not identify you. We use this information to better understand how users interact with the Service and to improve your user experience while using the Service. 

Do Not Track Signals.

We do not track you or collect your information across third-party websites or online services. Thus, we do not receive Do-Not-Track signals or other similar signals. To the extent that we do receive any such signals, we will not comply with them as it is not an aspect of the functionality of our Service.

Recording Policy.

School records School sessions via audio- and video-conferencing software from time to time. The purpose of such recordings is to facilitate marketing and periodic program reviews by accreditors and School administration.

Student consent is obtained each time a session is recorded, and Students who prefer to participate via audio only will be allowed to disable their video camera so that only audio is captured. Students should discuss this option with their teachers. If a Student does not consent to being recording for a particular session, Student will be given the opportunity at the beginning of the session to remove Student’s name from the recording software’s visibility for such session, and any participatory activity attributed to Student for such session will be removed from the recording prior to use.

4. HOW WE SHARE YOUR INFORMATION 

We do not sell or share your personally identifiable information with advertisers. We also do not share your personally identifiable information with other third parties except to the extent that it is in furtherance of the Service, or when you choose to do so (as described below).

School Directory.

To facilitate School communications and community-building, we place Student family information, including name(s), home address(es), email address(es), and telephone numbers of Parent, Student and other students in attendance at the School, in a directory (the “Directory”) made available to School families.

We do not share the Directory or information contained therein with commercial third parties or any person other than other School families. While we require all Sora enrollees to agree to the same and strive to ensure and enforce compliance, we do not retain control over actions taken by School families. If you wish to opt out of inclusion in the Directory, please contact privacy@soraschools.com.

Our Personnel And Vendors

To be able to effectively provide you with the Service, and to improve the functionality of the Service, we may disclose your information to our employees, contractors, agents, vendors, and other similar persons or entities, to the extent that such persons or entities have a need to know such information in furtherance of the Service. Our third-party vendors (“Third-Party Vendors”) provide us with various types of services, including without limitation, hosting services and marketing software services. We may share your Personal Data with our Third-Party Vendors.  

Third-Party Payment Services. 

We may share your personal information, including your name, with our third-party payment processing providers to allow you to make purchases or payments related to the Service. All payment information, including credit card number, will be collected and stored by our payment partners (“Payment Partners”). All purchases made through the Service are subject to the applicable Payment Partner’s privacy policy, and by making a purchase or payment through the Service, you agree to be bound by such policies. This includes, but is not limited to, the Stripe Privacy Policy, which may be viewed at https://stripe.com/privacy.

Sale of Company or Assets

In the event that we sell all or substantially all of our company or its assets, including the user information collected through our Service, we may transfer your information, upon reasonable notice to you, to the acquiring company. 

Other Third Parties

In addition to our practices described above, we may share your information if we have a good-faith belief that such action is necessary to (1) comply with the law (see the section below on “Government Requests”), (2) protect and defend the rights or property of Sora, or (3) prevent an emergency involving danger of death or serious physical injury to any person.

5. STORING YOUR INFORMATION

Storage and Retention Of Your Information

We use commercially reasonable managerial and technical safeguards to preserve the integrity and security of your personal information.

We cannot, however, ensure or warrant the security of any information you transmit to Sora or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by breach of any of our managerial and technical safeguards. As such, we will not be liable for any loss or damage you incur as a result of a breach of our security systems. In the event that personal information is compromised as a result of a breach of our security systems, we will promptly notify those persons whose personal information has been compromised as required by applicable law.

Security

We use reasonable efforts to secure your information and to attempt to prevent the loss, misuse, and alteration of the information that we obtain from you. For example, we require our personnel to sign confidentiality agreements that extend to your personal information, we have in place incident response measures, we have personnel to monitor privacy-related correspondence, and we review the privacy practices of new products and services that we integrate into our Service. In addition, we use reasonable technical safeguards, such as encryption, to secure your Personal Data, and we rely on the technical safeguards provided by the third-party vendors we use to host, store, and process your information. However, you acknowledge and agree that loss, misuse, and alteration may occur despite our efforts to protect your information. We are not responsible to our users or to any third party due to any such loss, misuse, or alteration. 

6. GOVERNMENT REQUESTS

From time to time, we may receive requests from government agencies to obtain information about our users. In handling such government requests, we greatly value the privacy of your information. While we may be required to turn over user information at times, we will strive to require a search warrant or subpoena, to the extent that we can reasonably demand such warrant or subpoena, before we turn over information about you and we will also strive to notify users when we receive government requests about their data. 

7. THIRD-PARTY SERVICES AND PRACTICES ARE BEYOND OUR CONTROL

Our Service utilizes third-party services as part of the functionality of the Service, such as hosting services, analytics providers, and other vendors, and we may share your information with third parties to the extent explained in this Policy. Additionally, we use third-party payment processing services. We have no control over such third parties. Thus, we make no guarantees about, and assume no responsibility for the information, services, or data/privacy practices of third parties, which may differ significantly from our practices described in this Policy. We encourage you to review the privacy practices of such third parties.

8. CHANGES TO THIS POLICY

Sora reserves the right to change this Policy from time to time, with or without notice to you. If you continue to use the Service, you consent to the new Policy. Sora will always have the latest Policy posted here on Sora’s website, available at https://soraschools.com/privacy-policy.

9. CALIFORNIA PRIVACY STATEMENT

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at privacy@soraschools.com or write to us at 3343 Peachtree Rd. NE, Ste. 145-606, Atlanta, GA 30326. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

We will retain your information as long as needed to provide you with our Service. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, enforce our agreements, or as otherwise described in this Policy. 

10. PLEASE REACH OUT TO US WITH ANY QUESTIONS OR FEEDBACK

If you have any questions about this Policy or our Service, please feel free to contact us by email at privacy@soraschools.com