iTutorGroup - Privacy Policy

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Tutor Group Limited ("we", "our", "us" or "iTutorGroup") respects the privacy rights of users and visitors ("you" or "your") of the iTutorGroup website (at www.itutorgroup.com) and/or iTutorGroup mobile application and services provided via these (together, "iTutorGroup Platform").

For the purposes of the General Data Protection Regulation of the European Union ("GDPR"), the data controller (being a responsible party as defined in terms of applicable data protection laws) of your personal data (which includes reference to "personal information" as defined in terms of applicable data protection laws) is Tutor Group Limited, whose registered address is Flat/Rm A 12/F Kiu Fu Commercial Bldg 300 Lockhart Road Wan Chai, Hong Kong.

We will collect, use, disclose or otherwise process your personal data in accordance with this privacy policy ("Privacy Policy "). Please read it carefully before sharing your personal data with us.

If you are not located in the UK or the EU or any other jurisdiction where processing of personal data is pursuant to legitimate interests, we will only collect, use, disclose or otherwise process your personal data with your consent or as authorized or required by applicable law. By clicking the relevant "AGREE" button, using the iTutorGroup Platform or otherwise providing us with personal data, you agree that we may collect, use, disclose, store or otherwise process your personal data in accordance with this Privacy Policy.

Topics:

1. Collecting personal data

1.1 Personal data we collect from you

When you create an account on the iTutorGroup Platform and apply to be a consultant, you will be required to provide your name, email address, mobile phone number, password, gender, nationality, current country of residence, education history and qualifications, teaching experience and teaching certificate and spoken languages and any other information you may provide in connection with your application.

When engaged as a consultant, you may also be required to provide your current address, identity verification, bank account or other payment details, a photograph, an introductory video and a written biography. You may also be required to upload your teaching materials onto the iTutorGroup Platform.

We may also collect special categories of personal data (known as sensitive personal data or special personal information in some jurisdictions), including your voice, speech patterns, mannerisms and facial images. In some jurisdictions where applicable under data protection laws, our collection of such data is subject to us having lawful bases for processing such data. Please see Appendix A below for further information.

You do not have to provide personal data to us, but if you choose not to provide personal data indicated as mandatory (e.g. on our application form), we may not be able to provide our services or otherwise engage or communicate with you.

If you are a California resident, please also refer to Appendix C.

1.2 Personal data we collect about you

1.2.1 Interview records

If you attend any online interview with iTutorGroup via video conferencing, we may record all or part of such interviews.

1.2.2 References and background checks

We may collect information about your employment history and qualifications, and subject to applicable legal restrictions, background and criminal records checks, from third party or publicly available sources and we will obtain your consent to such background checks where required by applicable law.

1.2.3 Recordings and content

If and to the extent permitted by applicable law, we may collect recordings and content from you if you require our troubleshooting support on live chats and/or emails.

1.2.4 Log records

When you log into the iTutorGroup Platform, we automatically receive and record information from your device, including device ID or IP address, and account's log information, such as the applications from which you entered the iTutorGroup Platform, the applications to which you head when you leave the iTutorGroup Platform, the amount of time you spend on the iTutorGroup Platform, as well as your behaviors on the iTutorGroup Platform.

1.2.5 Cookies

When you visit the iTutorGroup Platform, we may use cookies to collect the details of your visits, and to distinguish you from other users of the iTutorGroup Platform. A cookie is a small file containing a string of characters that is sent to your computer or mobile device when you visit a website or an application. When you visit the website or application again, the cookie allows that website or application to recognize your web browser. Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access the functionalities on the iTutorGroup Platform correctly or at all. For detailed information on the cookies we use, the purposes for which we use them, and how you can exercise your choices regarding our use of your cookies, please see Appendix B below.

We also work with third party ad networks to display more relevant advertising on our iTutorGroup Platform and to manage our advertising on third party sites, mobile apps and online services. For more information about cookies and other tracking mechanism as well as your choices please refer to Appendix B.

Our Site does not respond to do-not-track signals. For more information about do-not-track signals, please click here. You may, however, disable certain tracking as discussed in Appendix B (e.g., by disabling cookies).

1.2.6 Other sources

We may also collect your personal data from:

2. Using your personal data

We will use and otherwise process your personal data for the following business and commercial purposes:

2.1 Application processing

2.2 Managing your engagement as a consultant

2.3 Communications, marketing and advertising

2.4 Management of the iTutorGroup Platform

2.5 Business Operations

2.6 Compliance purpose

3. Sharing your personal data

We may share some or all of your personal data with the following:

4. International data transfers

In order to operate the iTutorGroup Platform and to provide our services, we may need to transfer your personal data to locations outside the jurisdiction in which you live, including but not limited to Hong Kong SAR, Mainland China, Taiwan and the United States of America.

These jurisdictions may not provide a level of protection consistent with the laws and regulations of the jurisdiction in which you live. If that is the case, we will put in place reasonable measures to ensure that your personal data will be protected to a standard that is comparable to those laws and will comply with applicable data protection laws in relation to the transborder flows of personal data.

Your personal data may therefore be accessible to law enforcement and/or regulatory authorities in such foreign jurisdictions according to the applicable laws of such jurisdictions.

If you are based in the UK or the EU, we will only transfer your personal data out of the UK or the European Economic Area ("EEA") (as the case may be) if:

Where South African data protection laws apply, to the extent that we transfer any special personal data or personal data relating to children to third parties located in jurisdictions that do not have adequate data protection laws as provided for under the jurisdiction in which you live, we shall do so only with the requisite prior authorisation of the data protection authority, in circumstances where required.

5. Retaining your personal data

It is important to let us know if there are changes to your personal data (e.g. if you move house). Please see "Contact Us" below.

We keep personal data of applicants during the application and selection process, and for two years afterwards for unsuccessful candidates or for such longer period as may be permitted or required by applicable law.

We keep personal data of consultants for the duration of the consultancy engagement and thereafter for as long as is necessary for the purposes for which the personal data was collected or used or for such longer period as may be permitted or required by applicable law.

We keep personal data of other users of the iTutorGroup Platform for as long as is necessary for the purposes for which it was collected and used (or a directly related purpose) or for such longer period as may be permitted or required by applicable law.

6. Security

We are committed to keeping the personal data provided to us secure and we have implemented measures to protect the personal data that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, no data security measures can guarantee security.

7. Automated decision-making

We may use automated decision-making, if it is authorized by legislation, if you have provided an explicit consent or if it is necessary for the performance of a contract. You can always request a manual decision- making process instead, express your opinion or contest decision based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you.

8. Links to other websites

The iTutorGroup Platform may contain links to other sites whose information practices may be different from ours. You should consult the other sites' privacy notices as we have no control over information that is submitted to, or collected by, these third parties.

9. Referral of friends

If you choose to refer a friend or family member to the iTutorGroup Platform or otherwise to us, for example by providing their email address to us, you must provide them with a copy of this Privacy Policy before providing their personal data to us. You hereby confirm that you have obtained their consent to share their personal data with us.

10. California's "Shine the Light" law (Cal. Civ. Code § 1798.83)

California residents who provide us their personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use; such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year (so, requests submitted in 2020 would be applicable to relevant disclosures (if any) in 2019). If you are a California resident and would like to make such a request, please submit your request in writing by emailing us at recruiting@itutorgroup.com, using the subject line "Request for California Privacy Information." In your request, please attest to the fact that you are a California resident and provide a current California address. We will reply to valid requests by sending a response to the email address from which you submitted your request. Please note that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.

11. Children

Our Services are not targeted to children (under eighteen (18) years of age or, in the US, under thirteen (13) years of age) and we do not knowingly collect personal information from children. If we discover that a child has provided us with personal information, we will promptly delete such personal information from our systems.

12. Your data subject rights

You may have the following rights in relation to the personal data we hold about you, and we will respond to such requests, in accordance with applicable laws:

In respect of the South African Information Regulator, you may contact the office at: complaints.IR@justice.gov.za and at 27 (0) 10 023 5200 or 33 Hoofd Street Forum III, 3rd Floor Braampark, South Africa, Braamfontein, Johannesburg.

13. Contact us

If you have any questions about this Privacy Policy, or want to exercise your rights set out in Privacy Policy, please email recruiting@itutorgroup.com.

14. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time. Where it is practicable, we will notify you by email of any material changes, and we will obtain your consent to such changes if required to do so by applicable law. However we encourage you to review this Privacy Policy periodically to be informed on how we use your personal data.

15. For California Residents

If you are a California Resident, the following section also applies:

The information in this Privacy Policy (including Appendix C) is intended to provide an overall description of our collection and use of personal information about you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information. In this section and in Appendix C, "personal information" is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

This Privacy Policy was last updated on January 12, 2020.

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CONSENT (if you are not resident in the UK or the EU)

By clicking below, you hereby consent to the collection, use, disclosure and other processing (including, without limitation, direct marketing communications and overseas data transfers) of your personal data (including where applicable your sensitive personal data, if any) by Tutor Group Limited as described in detail in our Privacy Policy (https://join.itutorgroup.com/privacypolicy/privacy.html).

By clicking below, you hereby consent to receipt of direct marketing of goods or services to be marketed by means of electronic communications by Tutor Group Limited as described in detail in our Privacy Policy (https://join.itutorgroup.com/privacypolicy/privacy.html).

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CONSENT LANGUAGE FOR BIOMETRIC DATA (if you are resident of Illinois, Washington and Texas)

By clicking the "Allow" button, you understand and agree that iTutorGroup may record your voice patterns and image and store your facial geometry for the purposes of matching your facial features against your photo ID for identity verification and validation purposes. We will disclose your biometric data to our vendors (if any) who assist us in operating the iTutorGroup Platform and may also disclose such data to other parties to protect our rights and interests and the rights and interests of other persons, or otherwise with your permission. We will retain your voice recordings and facial geometry data until, and will request that our vendors permanently destroy such data when, the first of the following occurs: (a) the initial purpose for collecting or obtaining such data has been satisfied, or (b) within 3 years of your last interaction with us. You may withdraw your consent at any time by contacting us as set forth in our Privacy Policy (https://join.itutorgroup.com/privacypolicy/privacy.html).

Archived versions

2019-11-26
2020-09-28

APPENDIX A

LAWFUL BASIS OF PROCESSING

No. Purpose for processing The lawful basis we rely on
1. Application processing

Process your application as a consultant

Some of this processing is necessary for takings steps at your request to enter into a contract with you.

Additional processing is necessary for the purpose of the legitimate interests pursued by us.

We have a legitimate interest in fully assessing consultants to ensure the selection of suitable and appropriate tutors.

We aim to onboard the best consultants and this contributes towards meeting our business objectives, maintain our reputation and attracting high caliber consultants.

To the extent that there is any processing of special personal information for purposes of the application processing, we will rely on your consent in circumstances where required by applicable laws.

2. Pre-contractual verification and screening

Appropriate screening including, where relevant and appropriate, identity check, financial sanction check, criminal record checks (if and to the extent permitted by applicable laws), and relevant professional and educational qualifications.

Some of this processing is necessary for compliance with legal obligations to which iTutorGroup is subject including establishment of the right to work or background checks for foreign education consultants.

Screening which is not legally required is necessary for the purpose of the legitimate interests pursued by iTutorGroup, where permitted by applicable laws.

iTutorGroup has a legitimate interest in ensuring that consultants do not pose an unacceptable risk to the business or its clients and considers the verification carried out necessary to prevent crime and other unlawful acts and to protect the business and clients from fraud, dishonesty or incompetence.

To the extent that there is any processing of special personal information for purposes of screening, and such processing is not necessary for the establishment, exercise or defence by iTutorGroup of a right or obligation in law, we will rely on your consent in circumstances where required by applicable laws.

3. Contract and onboarding

Providing contracts of engagement and preparing to commence engagement with us.

Some of this processing is necessary for the compliance with legal obligations to which iTutorGroup is subject including the requirement to issue written particulars or terms of engagement.

Additional processing is necessary to take steps to enter into the contract between you and iTutorGroup and to perform that contract.

To the extent that there is any processing of special personal information for purposes of the contract and onboarding process, and such processing is not necessary for the establishment, exercise or defence by iTutorGroup of a right or obligation in law, we will rely on your consent in circumstances where required by applicable laws.

4. Managing your engagement as a consultant
Managing and administering your engagement as a consultant, including without limitation arranging class scheduling, feedback and payment for your services;
Display your profile, experience and credentials to students you may tutor via, and users of, our services and platforms;
Facilitate classes with students you may tutor or users of our services and platforms;
Update your profile when requested by you or otherwise required by applicable law; and

We will use and otherwise process your special categories of personal data for the following purpose:

  • Verify your identity;
  • Detect potential imposters or fraudsters who may be using our services and platforms fraudulently or illegally;
  • Where applicable display your photograph and facial images on your profile.

Some of the processing is necessary to perform the contract between you and iTutorGroup to ensure that you carry out your obligations under your contract of engagement.

Further processing is necessary for the purpose of the legitimate interests pursued by iTutorGroup.

iTutorGroup has a legitimate interest in managing its consultants and operating its business. This includes ensuring the effective allocation and organisation of work amongst consultants and ensuring that each consultant undertakes appropriate duties in accordance with appropriate procedures.

iTutorGroup also has a legitimate interest in contributing to appropriate business protection by ensuring that consultants can be identified and to prevent imposters posing as approved consultants.

It also includes facilitating, controlling and restricting access to the iTutorGroup Platform and other iTutorGroup systems. To be effective these must be monitored and kept up to date.

To the extent that there is any processing of special personal information for purposes of the managing your engagement as a consultant including the display of photographic and facial images, we will rely on your consent in circumstances where required by applicable laws.

In addition to our legitimate interests where reliance on such lawful basis is permitted by applicable laws, any processing of special categories of personal data for identification and detecting imposters or fraudsters will be carried out based on your explicit consent. Alternative verification mechanisms may be provided where these would achieve similar standards of verification and authentication.

5. Communications, marketing and advertising

Communicate with you in respect of the services we provide via the iTutorGroup Platform or when you otherwise engage with us via the iTutorGroup Platform;

Send you marketing communications or advertisements from or about us or our Affiliates in relation to our products and services (including but not limited to newsletters, events and promotions); and

Enable selected third parties to send marketing communications which are related to their products or services which we think may be of interest to you.

Using your data to communicate with you is necessary for the compliance with legal obligations to which iTutorGroup is subject including the need to communicate with you regarding processes governed by laws (e.g. a consultation exercise or investigation).

Additional processing is necessary to perform the contract between you and iTutorGroup. There needs to be communication between you and iTutorGroup to operate your contract.

Further processing is necessary for the purpose of the legitimate interests pursued by iTutorGroup.

iTutorGroup has a legitimate interest in managing its workforce and operating its business. This includes effective communication and maintaining a dialogue with consultants operationally and in relation to their terms and conditions of engagement.

Communication is important to support the effective organisation and delivery of work and support successful delivery of commitments to clients and enable effective business performance.

Marketing communications will be sent in our legitimate interests or to the extent that consultants have consented to receiving such communications, where required by applicable laws.

6. Management of the iTutorGroup Platform

Enable us to operate the iTutorGroup Platform;

Carry out support and maintenance functions; provide you with necessary assistance in case of any technical issues;

Conduct data analysis and research, further develop and enhance the functionality and features of the iTutorGroup Platform; and

Deploy security measures for the iTutorGroup Platform.

Some of this processing is necessary for the purpose of meeting iTutorGroup's contractual obligations to provide you with tools and support in the provision of the services.

Further processing is necessary for the purpose of the legitimate interests pursued by iTutorGroup.

iTutorGroup has a legitimate interest in ensuring that the iTutorGroup Platform meets and operates to market standards for the provision of its services to clients.

7. Business Operations

Carry out our internal business functions such as quality control, headcount planning, reporting management;

Protect our intellectual property and other rights;

Enforce our internal policies and/or contractual rights; and

Conduct necessary investigations and disciplinary actions.

Some of this processing is necessary for the compliance with legal obligations to which iTutorGroup is subject including statutory reporting obligations and corporate governance requirements.

Additional processing is necessary for the purpose of the legitimate interests pursued by iTutorGroup.

iTutorGroup has a legitimate interest in managing its workforce and operating its business, ensuring appropriate governance and controls are in place and to measure and report on financial management and business performance.

This includes appropriate preparation of management information reports; financial accounts; reporting for internal and external governance; and liaising with third parties such as investors or finance providers.

iTutorGroup also has a legitimate interest in ensuring that its business, clients, consultants and systems are protected.

While we engage in management procedures with a view to addressing and resolving concerns we also need to ensure that any ultimate decision to bring your contract to an end is fair and lawful. This processing is necessary to perform the contract between you and iTutorGroup where we have committed to comply with certain procedures as part of your terms and conditions of engagement.

iTutorGroup has a legitimate interest in managing its consultant pool and operating its business. This includes putting in place appropriate policies and procedures for consultants and taking action if they are not complied with. It also includes addressing consultant concerns and issues, resolving the same and complying with our policies and procedures.

These activities support business continuity and are important to support the iTutorGroup's long-term business goals and outcomes.

To the extent that there is any processing of special personal information for business operational purposes, and such processing is not necessary for the establishment, exercise or defence by iTutorGroup of a right or obligation in law, we will rely on your consent in circumstances where required by applicable laws.

8. Compliance purpose

Comply with applicable laws, regulations, legal process (such as a court order or subpoena), governmental request, our internal policies and procedures, and other ethics, anti-corruption and compliance reporting tools;

Protect our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, health and safety compliance, regulatory, investigative, grievance and disciplinary purposes;

Detect, prevent or address fraud, security or technical issues; and

Protect us and you, and our, your or others' rights, property or safety, or the public against harm, as required or permitted by law.

This processing is necessary for the compliance with legal obligations to which iTutorGroup is subject where there is a legal obligation to disclose information or a court or other legal order to provide information is place.

Where not legally required, processing is necessary for the purpose of the legitimate interests pursued by iTutorGroup.

iTutorGroup has a legitimate interest in co-operating with relevant authorities, government bodies or regulators for the provision of information where appropriate.

iTutorGroup wishes to maintain its reputation as a good corporate citizen and to act ethically and appropriately in all the jurisdictions in which it does business.

iTutorGroup has a legitimate interest in protecting its organisation from breaches of legal obligations owed to it and defending itself against litigation. This is necessary to ensure that our legal rights and interests are protected appropriately, to protect our reputation and to protect us from other damage or loss.

To the extent that there is any processing of special personal information for general compliance purposes, and such processing is not necessary for the establishment, exercise or defence by iTutorGroup of a right or obligation in law, we will rely on your consent in circumstances where required by applicable laws.

This encourages compliance and high standard of business practice and protects our reputation. This supports our immediate and long-term business goals and outcomes.

9. Safety, security and preventing and detecting inappropriate or unlawful activities

Safety and security; satisfying the Company's regulatory or other obligations to supervise consultants; and preventing, detecting and investigating a wide range of activities and behaviours and liaising with regulatory authorities.

Some of this processing is necessary for the purpose of the legitimate interests pursued by iTutorGroup.

iTutorGroup has a legitimate interest in ensuring that its business, clients, employees and systems are protected and that action is taken to mitigate risk and to prevent and detect matters which may put iTutorGroup or its business or stakeholders at risk.

This includes carrying out risk assessments; detecting and preventing crimes or criminal activity or other unlawful or unethical activity; ensuring that only appropriate consultants are engaged in our business; and ensuring compliance with other legal or regulatory requirements placed upon us or related official guidance.

To the extent that there is any processing of identifiable special personal information for safety and security purposes and for the prevention and detection of inappropriate or unlawful activities, and such processing is not necessary for the establishment, exercise or defence by iTutorGroup of a right or obligation in law, we will rely on your consent in circumstances where required by applicable laws.

10. Sharing your personal data

We may share your personal data with the following:

  • our affiliates within the iTutorGroup group of companies,
  • students you may tutor via, and users of, our services and platforms;
  • our (and/or our Affiliates') service providers who support our provision of the iTutorGroup Platform, our services and our business;
  • Government, enforcement or regulatory authorities in any applicable jurisdiction;
  • outside parties involved in a merger, acquisition or due diligence exercise; and
  • anyone you authorise.

iTutorGroup has a legitimate interest in ensuring that it can engage with suppliers effectively and that suppliers can access the information they need to provide the service for which they have been engaged.

Effective communication with and engagement of suppliers is important for business continuity and improvement.

iTutorGroup has a legitimate interest in providing tutoring packages, which may include recording of tutoring sessions to students. Note that our clients also have legitimate interest in retaining such packages.

Some of this processing is necessary for the compliance with legal obligations to which iTutorGroup is subject

Additional processing is necessary for the purpose of the legitimate interests pursued by iTutorGroup.

iTutorGroup has a legitimate interest in managing its business operations in the most effective way. iTutorGroup needs to make decisions relating to the future of its business in order to preserve its business operations, grow its business or maximise efficiency and effectiveness.

In the event that iTutorGroup makes a decision to outsource a function or acquire or transfer a business or part of a business iTutorGroup and the third party with whom iTutorGroup is seeking to transact each have a legitimate interest in ensuring that the workforce, employee costs and liabilities are sufficiently understood prior to committing to the transaction and to ensure a smooth transition of employees if a transaction goes ahead.

To the extent that there is any disclosure or sharing of special personal information with third parties, we will rely on your consent to such disclosure and sharing of personal data in circumstances where required by applicable laws.

APPENDIX B

COOKIES POLICY

1. Introduction

1.1 Tutor Group Limited ("we", "our" or "us") uses cookies on the iTutorGroup website (at www.itutorgroup.com) and/or iTutorGroup mobile application (together, "iTutorGroup Platform"). The information set out in this policy is provided in addition to our privacy policy ("Privacy Policy"), and should be read alongside our Privacy Policy (https://join.itutorgroup.com/privacypolicy/privacy.html).

1.2 Cookies are small text files that are placed on your computer or mobile device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide web services and functionalities for users. For example, they enable you to improve your experience on the iTutorGroup Platform and enable the iTutorGroup Platform to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the iTutorGroup Platform or browse from one page to another.

1.3 You do not need to have cookies turned on to visit most of the iTutorGroup Platform. However, having cookies switched on should allow for a smoother and more tailored browsing experience, and is required for certain parts of the iTutorGroup Platform's functionality. In the majority of cases, a cookie does not provide us with any personal information.

1.3.1 Types of cookies

Cookies may be either "persistent" cookies or "session" cookies. The iTutorGroup Platform uses both persistent and session cookies.

A persistent cookie consists of a text file sent by a web server to a web browser, which allows us to collect and analyze (on an anonymous basis) traffic and use of the iTutorGroup Platform, monitor the system and improve operating performance, for example, store your preferences to enhance your subsequent visits. It will not be automatically deleted when the browser is closed but is stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date).

A session cookie is essential to ensure the correct functioning of the iTutorGroup Platform and is used to manage registration/login and access to reserved features. It is stored temporarily during a browsing session will expire at the end of the user session, when the web browser is closed. This iTutorGroup Platform uses both persistent and session cookies.

A complete list of the cookies we use is set out in the table at the end of this policy. This list (together with the rest of this policy) is subject to change from time to time.

1.3.2 Other tracking technologies

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with the iTutorGroup Platform and services to, among other things, track the activities of visitors and users of iTutorGroup Platform, help us manage content, and compile statistics about usage of iTutorGroup Platform. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Local Storage Objects. We may use Flash Local Storage Objects ("Flash LSOs") to store your preferences on iTutorGroup Platform and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose "Global Storage Settings Panel" and follow the instructions. To see the Flash LSOs currently on your computer, choose "Website Storage Settings Panel" and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

Third Party Ad Networks. We use third parties such as network advertisers to serve advertisements on iTutorGroup Platform, third-party websites or other media (e.g., social networking platforms). This enables these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party's specific privacy or cookies policy, not this one.

1.3.3 Our use of cookies

We do not automatically capture or store personal information from browsers to the iTutorGroup Platform, other than to log your IP address (which in certain circumstances will be your personal data) and session information such as the duration of the visit to our site and the nature of the browser used. This information is used only for administration of the iTutorGroup Platform and in the compilation of statistics which we use for analysis in order to improve the iTutorGroup Platform and understand in general terms who uses our Website.

Cookies may be required to allow you to access and participate in certain areas of the iTutorGroup Platform. Once you have closed your browser, this type of cookie is deactivated. Like all cookies, you are able to remove or block particular cookies at any time (see below).

1.3.4 Your cookie choices

The majority of browsers will allow you to alter the settings used for cookies and to disable and enable them as you require.

You can reject all cookies (except strictly necessary cookies) in case you prefer not to receive them, and you can have your computer warn you whenever cookies are being used. You can delete the cookies that are already on your computer and you can set your browser to prevent them from being placed. Disabling cookies may, however, prevent some web services (including on iTutorGroup Platform) from working correctly. Please be aware that when you have set your computer to reject cookies, it can limit the functionality of the iTutorGroup Platform and it is possible then that you will not have access to some of the features on the iTutorGroup Platform.

To disable cookies, or to receive a warning whenever cookies are being used, you have to adjust your browser settings. You can adjust your browser settings to delete certain cookies. Visit the "help" section of your browser for how to manage your cookie settings, or follow the links below:

For further general information on cookies and more detailed advice on how to disable and enable them please go to http://www.allaboutcookies.org.

Opting-out of Third Party Ad Networks. You have the ability to opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.

LIST OF COOKIES USED

Below is a list of the cookies set on the iTutorGroup Platform and the purpose of each:

ASP.NET_SessionId Security token passed to our portfolio service
ASPSESSIONIDQQRCBDRR This cookie is used to transmit the session ID and keep the session.
IsAbleToAnswerHomework It is used to identify whether the consultants can review the homework for students so that we can assign the relevant classes to the consultants.
IsQaTest It is used to identify whether the account is a test account as our staff sometimes uses testing accounts to test the functions.
area It is used to identify which iTutorGroup entity engages the consultants.
cname It is used to identify the Chinese name of our consultants from China.
conName It is used to identify the English name of the consultants.
conSn It is used to identify the consultants' ID in our system.
conSnEncode It is used to identify the encrypted ID of consultants in our system.
consultantEmail It is used to identify the email address of consultants.
csn It is used to identify the encrypted ID of consultants in our system.
email It is used to identify the email address of consultants.
sajssdk_2015_cross_new_user It is used to capture the behaviour of consultants on the iTutorGroup Platform inserted by our software development kit partner.
sensorsdata2015jssdkcross It is used to capture the behaviour of consultants on the iTutorGroup Platform inserted by our software development kit partner.
sessionToken It is used to transmit the session ID and keep the session.
status It is to identify the status of consultants, such as "training", "probation", "active", "in-active", "close", "invalid".

APPENDIX C

CATEGORIES OF PERSONAL INFORMATION COLLECTED FROM CALIFORNIA RESIDENTS

Generally, we may collect the below categories of personal data about our applicants and consultants, to the extent permitted under applicable laws (and for the purposes called out in the main body of this Privacy Policy above):

Identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, device ID, email address, account name, social security number, or other government identifiers.
Paper and electronic records: records containing personal information, such as name, signature, photo, contact information, education and employment history, Social Security number and other government identifiers, financial or payment information.
Characteristics of protected classifications: such as sex, gender identity, age, citizenship status, or other characteristics of protected classifications under California or federal law. (Note: generally, this information is collected on a voluntary basis and is used in support of our equal opportunity and diversity and inclusion efforts and reporting obligations, or where otherwise required by law.)
Internet or other electronic network activity information: such as browsing history, search history, and information regarding interactions with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information related to your use of your devices, network or other information resource.
Audio, video and other electronic data: audio, electronic, visual, or similar information, such as photographs, call recordings, video recordings (e.g. your introductory video recordings, online video interview records) and other audio recordings.
Employment information: professional or employment-related information.
Education information: information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).