Privacy Policy.

This Privacy Policy (this “Policy”) describes the practices of My Robin for collecting, using, maintaining, disclosing, and otherwise processing (collectively, “processing”) the information that we collect from you or receive from others, as well as how we protect and secure your data. If you have additional questions regarding your rights under this Policy or any agreement you may have with My Robin regarding your data, please contact us. Please read this Policy carefully to understand our processing of your information and how we will treat it.

This Policy generally applies to the information that My Robin processes. However, this Policy is subordinate to any specific terms and conditions set forth in any contract for services or other agreement you may have with My Robin relating to a service or data.

Further, this Policy applies only to information My Robin processes. This Policy does not apply to information collected by My Robin’s clients, who may have their own privacy policies that apply to you. It is our policy, however, to treat all Personal Information received from our clients with the same or greater care that they use.

1. What information does My Robin collect?

My Robin generally collects what can be describes as Personal Information and Non-Personal Information. We collect this information when you provide it to us, when you purchase or inquire of our goods or services, and when you work with our business partners.

“Personal Information” is information that can be used to identify, locate, or contact you, a natural person, as well as any other information about you that we may connect with Personal Information, and including any information otherwise defined as personal information under applicable law. For example, Personal Information that we collect includes:

• Contact information such as your name, email address, phone number, physical address, username, and password;
• Relationship information such as your preferences or potential interest in My Robin goods and services;
• Transactional information such as purchases, services requested, customer service inquiries, session data, customer account activity, and other customer account information;
• Biographical information such as your name, email address, age, gender, race or ethnicity, zip code, and your educational institution;
• Academic information such as your grades and the results of standardized tests; and
• Behavioral information such as your attendance, disciplinary history, and responses to surveys My Robin may provide, but, with respect to surveys that may be considered protected information surveys under the Protection of Pupil Rights Amendment (“PPRA”), we will only collect this information after complying with PPRA’s requirements, providing notice, and obtaining consent.

“Non-Personal Information,” on the other hand, is information that does not identify you as a natural person and is not identifiable to you as a natural person. For example, Non-Personal Information that we collect includes:

• Cookies and other similar tracking technologies processed in a non-identifiable way;
• Information we anonymize by rendering it unidentifiable to a natural person;
• Information we aggregate by combining it with other data in such a way that no natural person can be identified or linked to any specific information; and
• The name, form, contact details, relationship information, transaction history, or financial information of legal persons. By “legal persons,” we refer to legal, business entities other than natural persons, such as corporations, limited liability companies, non-profit organizations, and other business entities.

2. Why does My Robin collect this information?

My Robin collects and processes Personal Information for a variety of purposes depending on the information being processed. My Robin processes Personal Information to serve you, the student, to deliver our goods and services to you, and to improve our goods and services while processing information as may be necessary to support you in their use. My Robin may also process Personal Information as may be necessary to comply with a legal obligation.

To summarize, My Robin processes Personal Information for the following purposes:

• To oversee and complete transactions with My Robin clients;
• To prepare, deliver, maintain, or otherwise provide My Robin’s goods and services;
• To support and improve My Robin’s goods and services;
• To set up and maintain your user account and allow you to interact with My Robin and other users of My Robin’s goods and services;
• To provide you with service by resolving disputes, addressing complaints, and troubleshooting any technical problems encountered;
• To measure and understand the effectiveness of My Robin’s goods and services; and
• To comply with applicable laws and regulations. Please note that if we are asked to provide Personal information pursuant to a lawful subpoena or court order, we will first notify you or your parent, unless a court has ruled otherwise. We will further endeavor to verify all requests and only to disclose the information legally requested.

If we would like to process your Personal Information for any other purpose, we will disclose this to you at the time it is collected and may request your express consent. In the event we seek to collect any personal information for the purpose of marketing activities or commercial use, we will only do so if addressed and permitted by your educational institution’s policies and only upon first providing prior notice and an opportunity to opt out of any such marketing activities.

With respect to Non-Personal Information, because this information does not identify a natural person My Robin may use and process it for other purposes, such as improving our goods and services. My Robin may use anonymized or aggregated information to improve or develop its goods and services, create and publish reports, conduct statistical analyses about client interest, monitor industry trends, and otherwise engage in activities that do not result in the disclosure of identifiable information.

To be clear, My Robin is committed to respecting its customers’ privacy and will only process your Personal Information for the reasons disclosed herein or as requested at the time of collection, and then only in the context of your customer relationship with My Robin. My Robin will not sell, rent, or lease your Personal Information to others.

3. Will My Robin share this information with third parties?

To provide certain services, My Robin may have to share information with third parties who use our goods and services or provide goods or services to us, such as our clients, service providers, vendors, or operators of software used in our services. For example, we may share your Personal Information with the following categories of third parties:

• Academic providers such as your educational institution, teachers, or supplementary remedial or advanced instructional providers, with whom we share information as necessary to serve you; and,
• Tech providers such as Amazon Web Services, Zoom, or certain products provided by Google, like Workspace or Gmail, with whom we may share information as necessary to deliver our services to you.We will maintain controls and oversight appropriate to ensure that any third party who we engage to assist us in processing your Personal Information will only have access to the Personal Information necessary for it to perform specific, designated tasks on our behalf, will only use the information for this purpose, and will protect your Personal Information to at least the same extent that we do. In other words, we will require our vendors with whom we share your Personal Information to be obligated to follow the same commitments we make to you.

Please note, however, that this Policy applies only to information that we process and share with others—it does not apply to Personal Information that you share with third parties.

My Robin may also share information to comply with our legal obligations, such as responding to lawful requests from government or judicial entities. In the event we are asked to disclose your Personal Information, we will attempt to validate the request and inform you of it prior to disclosure.

Finally, My Robin may disclose Personal Information where needed as part of a sale or transfer of our assets, enforce our rights, protect our property, or protect the rights, property, or safety of others, or as is needed to support external auditing, compliance, and governance functions. That said, any successor entity of My Robin will only be permitted to access Personal Information if they are subject to the same commitments we have made to you.

If My Robin needs to share your Personal Information for a purpose not identified here, we will obtain your consent before doing so and will disclose this purpose at the time of obtaining your consent. For example, My Robin may wish to use your information in demonstrations or other marketing materials and, if so, will contact you before doing so.

With respect to Non-Personal Information, because this information does not identify a natural person we may share it as we find appropriate to improve our services. For example, we may engage expert partners to lead reviews of anonymized, aggregated data that we can then use to ensure we are providing you with the best possible product. In the event we disclose anonymized or aggregated data, we will prohibit the recipient from attempting to re-identify any of this data.

4. How long will My Robin keep my information?

My Robin keeps different kinds of information for different lengths of time depending on the purpose for which it is processing the information and depending upon your specific situation. In any event, My Robin will retain your Personal Information as long as necessary to accomplish the relevant purpose, but no longer.

5. How does My Robin keep my information secure?

Taking into account the nature of the information gathered, My Robin maintains a comprehensive security program that is reasonably designed to protect the security, confidentiality, and integrity of your Personal Information through administrative, technical, and physical controls appropriate to the sensitivity of the information. When developing or improving our goods and services, we incorporate privacy and security into our design.

6. What are my choices with respect to my information?

Your first choice is always to limit the information you provide. You may also opt out of certain marketing information by visiting our website and communicating your choices to us, or by clicking “unsubscribe” at the bottom of marketing emails you might receive.

Regarding cookies and other tracking technologies, you can manage these by adjusting the settings on your browser, commonly referred to as the browser’s “Do Not Track” settings. All browsers are different, so you may need to visit the “help” section of your browser to learn more about cookie preferences and other privacy settings that may be available. You can also manage how your mobile device and mobile browser share location information with My Robin, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn more. In general, My Robin will comply with your browser’s “Do Not Track” settings.

My Robin will support your ability to access, correct, and delete your identifiable information. If you have an online account, you may be able to log into your account to access and update certain information provided. For identifiable information that is not linked to an online account, please contact us directly.

For assistance with exercising your choices, or if you have any questions about your choices, please contact us.

7. For California residents:

This notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

The California Consumer Privacy Act (the “CCPA”) affords those who reside in the State of California certain rights as a data subject. If you are a resident of the State of California, we encourage you to read and learn about those rights on your own, but the following will help you to begin to understand them:

• Access: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information.
• Erasure: In some cases, you may have the right to request that we erase your Personal Information in our possession.
• Data Portability: This allows you to request a copy of your Personal Information that we may have and transfer that information to someone else without any interference from us. In some cases, you may be able to request that we transfer your Personal Information directly to a third party on your behalf.
• The CCPA further provides California residents the right to direct us not to sell your personal information. WE DO NOT SELL YOUR PERSONAL INFORMATION.

We will not discriminate against you for exercising any of your CCPA rights.

The categories of Personal Information that My Robin collects from California residents are described in Section 1, above, and include contact information, relationship information, transactional information, biographical information, academic information, and behavioral information. The purposes for which My Robin collects this Personal Information is described in Section 2, above, and includes overseeing and completing transactions with clients; preparing, delivering, maintaining, and otherwise providing the My Robin goods and services you request; supporting and improving My Robin goods and services; setting up and maintaining your customer account and allowing you to interact with My Robin and other uses of My Robin’s goods and services; providing you with customer service by resolving disputes, addressing complaints, and troubleshooting problems encountered; measuring and understanding the effectiveness of My Robin goods and services; and complying with applicable laws and regulations. To the extent any Personal Information is processed for marketing activities or commercial use, we will only do so if addressed and permitted by your educational institution’s policies and only upon first providing prior notice and an opportunity to opt out of any such marketing activities.

In addition, under California’s “Shine the Light” law, we state to you that we do not share your Personal Information with third parties for their direct marketing purposes.

In addition, California’s Student Online Personal Information Protection Act (“SOPIPA”) and Early Learning Personal Information Protection Act (“ELPIPA”) may provide you with further protections for your Personal Information. Pursuant to SOPIPA and ELPIPA, My Robin does not knowingly engage in targeted advertising, develop student profiles for a non-K-12 school purpose, sell covered information to third parties except as part of a merger or business sale, or disclose covered information unless an exception applies. Further, My Robing maintains a comprehensive security program that is reasonably designed to protect the security, confidentiality, and integrity of your Personal Information through administrative, technical, and physical controls appropriate to the sensitivity of the information and will delete a student’s covered information on request of a school or district. To the extent permitted by SOPIPA and ELPIPA, My Robin may use covered information to maintain, develop, support, improve, or diagnose its services, and may also use de-identified covered information to improve its services or demonstrate their effectiveness. Finally, and to the extent permitted by SOPIPA and ELPIPA, My Robin may share aggregated, de-identified covered information to third parties as necessary to develop and improve its services.

To make a request regarding any of these rights or to ask questions or provide comments about this Privacy Notice for California Residents, please contact us.

It is our policy to post any changes to this Privacy Notice on this page. We may or may not contact you directly concerning significant changes. We encourage you to visit this page periodically and check for changes. To the extent permitted by law, your continued use of our services after a change is deemed to be your consent to any such change.

8. Your rights under FERPA.

Under the Family Educational Rights and Privacy Act (“FERPA”), your educational institution bears certain requirements and protections with respect to your Personal Information or education records. While not directly regulated under FERPA, as an education service provider we may be subject to certain provisions upon receiving your Personal Information or education records. These rights may include the right access, inspect, and review personal information; challenge and correct its contents; and prevent disclosure without prior written consent, subject to certain exceptions. In connection with FERPA, it is our policy to require your educational institution to comply with these requirements prior to disclosing any Personal Information or education records to us, and it is further our policy to support you or your legal guardians in the exercise of FERPA rights. Finally, we will use FERPA-protected information only for the purposes for which your educational institution provided this information to us, and we will further ensure that it is not redisclosed to others without the consent of you or your parents, unless an exception applies.

9. Your rights under COPPA.

The Children’s Online Privacy Protection Act (“COPPA”) regulates the online collection, use, and disclosure of the Personal Information of children under the age of 13. When and if applicable, My Robin complies with COPPA’s requirements, including those of, with few exceptions, obtaining verifiable legal guardian consent before processing the Personal Information of children under the age of 13, and providing these legal guardians the ability to review, correct, and prevent the further use or require the deletion of such Personal Information. My Robin further does not condition any child under the age of 13’s participation in any online activity on the child’s disclosing more personal information than is reasonably necessary for participation, and My Robin maintains such children’s personal information in a reasonably secure manner to protect its confidentiality, security, and integrity.

10. Our pledge to you and how you can get more information.

My Robin is proud to have taken the Student Privacy Pledge, which you can review here. As stated in our Pledge, we believe it is critical that schools and My Robin build trust by effectively protecting the privacy of student information and communicating with parents about how student information is used and safeguarded. If you have any questions about this Pledge, this Privacy Policy, or our information and data privacy and security practices generally, or if you wish to provide comments or exercise any of your rights with respect to your Personal Information, please contact us at info@my-robin.com.

11. Does this Policy ever change?

My Robin may post changes to this Policy on this page. Please refer to the “last updated” date above. Except where otherwise indicated in this Policy or where required by law, we may or may not contact you directly concerning certain changes, and therefore we encourage you to visit this page periodically and check. By using My Robin’s services or purchasing its goods after a change to this Policy, you are deemed to consent to any changes, unless otherwise provided by law.

Last Updated: March 30, 2021