Privacy Policy

Overview 

The Board of Jewish Education, Inc. d/b/a The Jewish Education Project (“TJEP”, “our”, “us”, or “we”) is a New York not-for-profit corporation, having its principal place of business at 520 Eighth Avenue, 15th Floor, New York, NY 10018. TJEP operates the Truvie website located at https://truvie.org.  

We understand how important privacy is to you, and we are committed to protecting your privacy and to creating a safe and secure environment for learners of all ages. This Privacy Policy explains how information is collected, used, shared, and protected by TJEP when you use (or access) our Truvie website and online service (as further described in Our Privacy Statement below). 

Because Truvie is a learning environment for children, we take additional measures to safeguard children’s privacy, including for children under the age of 13. Please see our Children’s Privacy Notice below. 

Our Privacy Statement 

Truvie is a service that allows registered parents or legal guardians (“Parents”) to enroll learners (“Learners”) in online small-group classes, and for registered teachers (“Teachers”) to create, publicize, and provide those classes (collectively, our “Service”). This Privacy Policy describes what personal information TJEP collects from registered Parents, Teachers, and Learners of the Service and how such personal information is used, as well as how TJEP collects and uses personal information from visitors to our public Truvie website (“Site”). Learners who use the Service do so in a learner mode called Learner Space which allows us to provide additional protections, including for children under the age of 13, as described in our Children's Privacy Notice. Access to and use of our Site and Service are subject to the Terms of Service.   

Collection of Information 

Use of Information 

Sharing and Disclosure of Information 

Transparency and Your Choice 

Do Not Track 

Your Account Settings 

Information Security 

Links to Third Parties 

Retention Policy 

Cookie Policy 

Other Terms and Conditions 

Changes to this Privacy Policy 

Contact TJEP 

Children’s Privacy Notice 

Regional Information 

1. Collection of Information 

We collect information in the following ways, depending on your use of the Service and your account settings: 

• We collect information from you directly, such as when you create an account, communicate with us, participate in activities, events or surveys, or otherwise provide information during your use of the Site or Service. 

• We may collect information from others, such as your Parent, Teacher, or third parties (meaning organizations outside of TJEP), such as third party applications that you use to connect to the Service. 

• We collect some information automatically, such as information about your use of the Site or Service and the devices you use to access the Service. We may use cookies, web beacons, and similar technologies to collect information as explained in our Cookie Policy. 

Information you provide to us 

• Contact and profile information. When you create an account we may collect information including your full name, physical address, telephone number, birthdate (for compliance purposes), and email (for compliance purposes). We also collect sign-in information including username and password. After you register, you may also choose to provide additional information in your profile, such as your nickname, and other personal or demographic information. 

• Your communications with us. We may collect information from you at other times, such as when you request customer support, send us an email, post a comment, complete a user survey, participate in a special program, or otherwise communicate with TJEP (including via third party services). 

• Payment information. Our payment processor will collect your credit card, debit card number or other payment information when you enroll in a class. 

• Demographic information. We may collect demographic information such as age, gender, preferred pronouns, marital status, and similar demographic details, such as when you voluntarily provide information in the “about me” section of your profile or communicate with us. 

• Health Information. Parents may voluntarily provide sensitive data such as health or disability information in forms or messages sent to Teachers to aid with learning. (Teachers and Learners are otherwise not allowed to have discussions that may elicit or result in the sharing of sensitive information). 

• Content and files. We collect information about (i) classes for which you have enrolled or indicated your preference through a “like” feature, (ii) video of your image and audio of your voice during classes which are automatically recorded, (iii) content and communications that you may include or upload like your profile photo or messages you share with the class, (iv) your voluntarily provided profile picture or your Facebook picture linked to your account, (v) information voluntarily provided through reviews of a class or the Service, (vi) notes you provide to the Teachers about yourself (or if you are a Parent, your Learner when enrolling a Learner in a class), and (vii) information Teachers provide to let us run background checks and background check reports we receive from third parties. 

• Information we collect to enable your participation in special programs or features. TJEP may feature a special program or activity we offer in partnership with a third party. If you participate in these special programs, TJEP may collect information from you to facilitate those programs.  

• Other information. We may also receive sensitive criminal history information about Teachers when we receive background reports. 

Information that we may receive about you from others 

• Information obtained from other users. We make available certain features on our Service that allow other users to provide us information about you. For example, a Parent may provide information relating to a Child User (as defined in the Children’s Privacy Notice), such as when a Parent registers an account for their Child and provides us with information about the Child User as described above. Please review our Children’s Privacy Notice for additional information about use of our Service by Children (as defined in the Children’s Privacy Notice). 

• Information from Single Sign On (SSO) authentication services. If you decide to register for an account (or access your account) through an authentication service (such as Google Accounts or Facebook as a Single Sign On, also known as a SSO) (“Authentication Service”), we may collect your name and email address from these third-party services, consistent with your privacy settings in your account with the relevant Authentication Service. 

• Information provided by partners and other sources. We may also receive information from third party organizations with which we partner to provide educational services.  For instance, we may collect information from: third party applications and services; joint partners; service providers, contractors, and vendors; publicly available sources; and public and government sources and records   

Information we collect automatically 

• Information about your use of our Service. We may collect usage information about your use of our Service, such as the number of classes taken, the number of videos you have viewed, and the amount of time spent using TJEP Services. This enables us to better tailor educational experiences that are most appropriate for you. 

• Location information. We may collect and use information about your location in the aggregate (such as your country) or infer your approximate location based on your IP address in order to provide you with tailored educational experiences for your region. You may be able to change the settings on your computer or mobile device to prevent it from providing us with any location information. 

• Usage and device information. To provide a personalized learning and high-quality experience for our users, we may use various technologies that automatically record certain technical information from your browser or device when you visit our Site, read our emails, use our Service or otherwise engage with us (e.g., the model of the laptop or mobile device and operating system version you use). You can learn more about our use of these technologies (and how to manage their use) in our Cookie Policy. 

Required Personal Information 

Some personal information is required such as credit card payment data used by Parents to purchase classes and for verified parental consent. Teachers are required to let us access Personal Data relating to background checks. Teachers are also required to have their cameras on while teaching a live class. Learners are required, subject to authorized exceptions, to have their video enabled at least at the start of class to verify their identity to protect the safety of other Learners. You may decline to provide certain personal information. However, where this personal information is required, in order for TJEP to comply with its legal or contractual obligations, failure to provide the personal information may mean we cannot provide the Service to you.  

2. Use of Information 

TJEP uses your information in the following ways and for the following purposes: 

• To provide our Service. TJEP uses your information to operate, maintain, and provide all of the features of our Service. TJEP will also use your information where requested by you, to facilitate your sharing of content on third party social media platforms. 

• To personalize your experience. We use your information to personalize your experience while using the Service, including on various devices you may use to access the Service. For instance, TJEP remembers your recent activity so we can recommend the most appropriate content for you on your next visit and provide personalized learning experiences. 

• To provide customer support. We will use your information to communicate with you to confirm registration and send updates, provide customer support and security alerts, respond to inquiries and to send other administrative messages. 

• To enable your participation in TJEP partnership arrangements. We use your information to enable your participation in programs or features we may offer in partnership with third parties, to the extent you decide to participate in such programs. 

• To conduct business operations. We use your information to conduct business operations, such as processing your payment for the Truvie Service, billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, meeting our legal obligations, and to conduct background checks, if you are a Teacher. 

• To evaluate, understand, improve, and develop our Service. TJEP uses information to understand and analyze the usage trends, learning behaviors, and preferences of our users, to evaluate and improve the way the Service works and looks, and to create new features and functionality. 

• To develop new educational offerings. We may use information to maintain, develop, support and improve our Service and other educational products and services, and for educational research. 

• For legal, compliance or safety reasons. We may use or share information to comply with applicable laws, rules, or regulations, and our Terms of Service, including protecting the safety and rights of TJEP, users, and the general public. 

We may combine data we collect from different sources to achieve the above purposes and to give you a more seamless, consistent, and personalized experience. 

TJEP records video of Children and Teachers during Truvie classes (“Class Recordings”). TJEP may provide Teachers a read-only copy of the Class Recordings for their specific classes that they teach in order to improve their class instruction and curriculum. Truvie may also use Class Recordings to provide feedback to Teachers, for customer support, and for compliance purposes. 

TJEP will obtain additional parental consent before we use any Class Recordings for promotional or other purposes. 

Direct Marketing Communications: If you are a Parent or Teacher, TJEP may, with your prior opt-in consent, use your contact data for marketing purposes, including to tell you about services and opportunities we believe will be of interest to you (including messages about new and recommended classes, events), and to communicate with you about our philanthropic mission and fundraising for our mission. If we do so, each promotional email we send you will contain instructions permitting you to "opt-out" of receiving future promotional information. In addition, if at any time you wish not to receive any future communications or you wish to have your contact information included in our opt-out lists, please contact us at info@truvie.org. Please note that we will continue to contact you via email to respond to requests and provide our services. 

For information regarding processing of personal information relevant for international visitors located outside of the United States, please review Regional Information. 

3. Sharing and Disclosure of Information 

We do not sell your personal information to third parties. This section explains circumstances in which we may share personal information with third parties. 

We may share personal information: 

• with other users of our Service, if you use features that enable you to share your information with (or make it accessible to) others. 

• with third-party vendors, consultants and other service providers working on our behalf such as credit card processors or educational or Service evaluators and consultants. 

• with other users that are associated with your account, such as a Parent, Teacher or coach; when Parents sign up they agree that Teachers may receive certain personal information about the Parents and their Learners including classes their Learner has taken. Teachers are not our employees, agents, or service providers, but we do issue guidance and restrictions on what they can do with Personal Data. We act as limited agents for the Teachers to process payments from Parents for Classes. Please note that in some cases, classes are taught by a “Teacher” that is actually an organization, group, or team of instructors (“Teacher Organization”). In such cases, Class Recordings may be accessible to the entire Teacher Organization, and access would not necessarily be limited to a single individual Teacher. 

• with other like-minded not-for-profit organizations and other entities to further our Jewish educational charitable mission. 

• with your consent, with third party applications that you choose to use, such as complementary services or an Authentication Service. If you choose to use a third-party application or service, the use of your information by the third party will be governed by that third party’s privacy policy.  

• in connection with business transfers (due to mergers and acquisitions). 

• for compliance purposes, such as when reasonably necessary to protect the security and safety of our users or Service, or when permitted by law. 

We may also share de-identified or aggregated information that does not reasonably identify any individual and/or constitute personal information under privacy laws. 

TJEP may share or transfer your information in the following ways: 

When information is visible to others on the Service by default 

Certain features and functions of the Service may share your information with or make it accessible to others. You may be able to share personal information, including communications, with third parties, including with the general public, through use of our Site or Service. When you do so we ask that you avoid sharing personal information and do not share sensitive personal information. 

We expect everyone to respect the privacy of others and follow our community standards, and other guidelines and restrictions on posting and sharing activities, such as sharing private materials, communications, or information, or sharing other personal information about others that may cause harm, embarrassment, or conflict. You should not encourage your Learners or other Learners to reveal any personal information about Learners or their families. 

For example, your information may be visible to others in the following circumstances: 

• User Profile: As a user of our Service, you will have a user profile that will be publicly available to all users of the Service (the “User Profile”). You are required to include first name and last name on your User Profile. But you will have the option to include a variety of types of personal information in your User Profile, which may include your avatar or personal photograph. We do not systematically monitor the content of information that is published on your User Profile. Any information published in your User Profile becomes available to the public. After publishing, we have no control over how such information is used or its further dissemination. We urge you to think carefully about what, if any, personal information you include in your User Profile. 

• Information you post to public spaces of the Service. When you post a question or answer to the Service, your profile, which could include your name and short biography, as well as the content of your posted comment, is visible to others on the Service. As with most online services, once your information is available to others online, it may be collected and used by the recipients or any other website visitor without restriction. As with online safety in general, consider which personal information (if any) you want to share in your profile or posts. 

• Information shared when your account is connected to another user account. When your account is connected to a Teacher or your Parent, that person will be able to see your profile information and your learning activity on the Service, such as which videos you have watched, the questions and responses you post, and other usage information. This information may include your name (not only your username) as well as information in your account profile and your account settings. 

• Online Classrooms and Pages: If you are Teachers or Learners attending our online classes, you may publicly display and share your video and photographic image, name and/or username and certain other information, such as your profile, demographic data, content and files, or imprecise location data. You may also use the chat function to communicate with other learners and the Teachers during a class session.  

• Public Forums: Our Service provides you the opportunity to share information on a variety of topics with other users through public forums (the “Public Forums”). Use of the Public Forums is entirely voluntary. But please be aware that any information you include in the Public Forums will become available to all Truvie Users without restriction. We do not systematically monitor the content of information that is published in the Public Forums. Any information published in Public Forums becomes available to the public. 

• Messages: Learners may message Teachers, Parents may message each other, and Parents and Teachers may message each other using the Service. Parents may have access to messages between their Learners and Teachers. After publishing, posting, or messaging, we have no control over how such information is used or its further dissemination. We urge you to think carefully about what, if any, personal information you share with others on our Service. 

Sharing of personal information with third parties 

We may share your information with third party applications or services in several ways: 

• We may share information with third-party applications that you authorize. Third-party application developers and service providers may build complementary services for our platform. They may also use our TJEP content to build unaffiliated applications and services. If you connect your TJEP account to a third-party application or service, or approve access to your TJEP account by a third party, you consent to TJEP sharing your information with that third party. Please note that these third parties are not governed by TJEP or the terms of this Privacy Policy. We recommend you review the privacy policy of any third party application or service before authorizing its access to your TJEP account information.  

• We may share information with third-party Single Sign On tools that you choose. TJEP provides you with opportunities to register an account with (and/or sign on to) TJEP by using a Single Sign On Authentication Service. If you choose to use the Authentication Service, these third-party services may be able to collect or infer information about you, including information about your use of our Service (i.e, your log-in activity), in accordance with their own privacy policies. We recommend you review their privacy policy before authorizing its access to your personal information. 

• We may share information with social networks at your request. You may choose to share TJEP content with others by email (or by posting to social media sites) through third party integrations with social media sites (like Facebook or Twitter). These third parties may use your information as described in their own privacy policies and we recommend that you review their privacy policies in advance of sharing any personal information with them. Use of this feature is optional. 

• We may share information in connection with special programs you participate in. If you participate in special programs where TJEP partners with third parties, TJEP may share information collected from or about you with its third-party partners to facilitate the program or services being offered. We may share information with your consent. TJEP does not share your information with for-profit third-party organizations for their marketing or promotional use without your consent. In some instances, you may be able to grant us permission to share your information with authorized for-profit partners and other entities that are not affiliated with TJEP. In these cases, we will only provide to these third parties the information you have authorized or asked us to share. Please note that these third parties are not governed by TJEP or the terms of this Privacy Policy. We recommend you review their privacy policy before authorizing access to your personal information. 

• We may share de-identified or aggregate information with others: In certain circumstances, TJEP may share de-identified or aggregated information that does not reasonably identify you as an individual and that does not constitute personal information under privacy laws, for various purposes. For example, we may share de-identified information with business partners to improve our Service or offerings or to conduct educational research. If we disclose information to third parties for research or product development purposes, such information will be aggregated and/or de-identified to reasonably avoid identification of specific individuals. 

• We will share information with service providers: In order to provide our Service, TJEP may share information with our vendors, third party service providers or other individuals, such as entities providing billing, credit card processing, customer support, Service and class evaluation / consultation, analytics, hosting, marketing and similar services. When we share information with third party service providers or vendors, these third parties are contractually obligated to maintain the security and confidentiality of that information. 

• We may share or disclose information for legal or business purposes: We may share information in the context of a change of business, including a merger or acquisition. In the event that TJEP is involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of our assets, your information may be transferred or disclosed in connection with such business transaction. Teachers are required to report to TJEP any suspected case of child abuse or neglect they become aware of during their work with Learners. Teachers may also be required to report suspected abuse or neglect to local authorities, and TJEP expects all Teachers to comply with their individual reporting responsibilities. TJEP itself may report instances of suspected abuse or neglect. 

• Other instances. TJEP may share or disclose information if we have a good faith belief that doing so is reasonably necessary to: (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) investigate or defend ourselves against any third-party claims or allegations; (d) detect, prevent or otherwise address fraud, security or technical issues; (e) protect the rights, property, or personal safety of TJEP, our users, or the public; or (f) as otherwise required or permitted by law. 

4. Transparency and Your Choice 

We take privacy very seriously. We strive to put you in control of the choices and decisions regarding your personal information. 

We understand that your personal information is important to you, and that is why you have choices in how your personal information is used and shared. We want you to have access to your personal information, so that you can help keep it as accurate as possible. 

For example, you can choose whether to create an account. If you register for an account, you can: 

• Limit optional information you provide 

• Choose whether you wish to share personal information with (and use) third party services 

• Choose whether you wish to receive optional email 

• Update and correct your account information through your account settings 

You may limit the personal information you provide: You can choose to provide information which does not reasonably identify you to others. For example, we recommend you select a username which is not related to your actual name (or could otherwise be used to identify you). You can also decline to provide any optional information in your public profile. 

Community forums are optional: You choose whether (and how) to participate in publicly accessible forums, such as posting to public spaces of the Service. When you post a question (or answer) to the Service (or otherwise participate in a public forum), your profile (as well as the content of your posted comment) is visible to others on the Service. Our Service offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others. Child Users are not able to post in community forums (as described in Children’s Privacy Notice). 

You can disconnect (or choose not to use) third party applications: You choose which third party applications you want to use and can stop using any such third party applications at any time. This functionality is optional, and entirely up to you. For instance, you can revoke TJEP’s access to your account on any single sign-on service at any time by updating the appropriate settings in the account preferences of the Authentication Service (or simply by not logging in through that Authentication Service). 

You can unsubscribe from optional email messages: TJEP may, from time to time, send you emails regarding our products and Service, or products and services we think you may enjoy. You can choose not to receive these emails by clicking the unsubscribe link in any e-mail or updating your Settings page. Please note that you are not permitted to unsubscribe or opt-out of certain types of messages regarding your account, such as account verification, changes or updates to features of the Service, technical or security notices and certain programmatic communications (such as class assignments). 

You can learn more about cookies and how to manage cookie settings in our Cookie Policy: Many web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. You also can directly opt out of certain third party cookies. Please note that choosing to remove or reject certain cookies might limit your use of the Service. For more information about our use of cookies and other similar technologies, please review our Cookie Policy. 

You can share information about courses you are studying through sharing features: We offer clearly marked sharing features, which allow you to share information about courses or topics you are learning about through the Service. Using the sharing features is entirely at your option. 

5. Do Not Track 

We do not track users over time and across third party websites to provide targeted advertising. Additionally, a “Do Not Track” (“DNT”) standard has not been adopted to this day. Therefore, we do not use or recognize DNT signals.  

However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user’s DNT preference. You can usually access your browser’s DNT option in your browser’s preferences. 

6. Your account settings:  

We want you to have access to your information, so that you can help keep it as accurate as possible. If you register and provide TJEP with information, you may update or correct your account and information at any time by reviewing your profile information and preferences on your account settings page. 

Parents (not Children) can modify or delete Child User accounts, as described in our Children’s Privacy Notice.  

Access, update, and correct your information: You may access, update, and correct your personal information at any time by logging into your account and updating the relevant information on your account settings page. 

Delete your account and information: To request deletion of your information at any time, please email info@truvie.org.  Unless we receive a deletion request, we will retain your information for as long as your account is active or as is reasonably useful for operational purposes. We may also retain information which has been de-identified or aggregated such that it can no longer reasonably identify a particular individual. 

7. Information Security 

To protect your personal information from unauthorized access and use, we implement and maintain security measures that are intended to maintain the confidentiality of personal information. However, no security measures are infallible and we cannot and do not guarantee that our safeguards will always work. Please always use caution when transmitting information, including over the internet. 

8. Links to Third Parties 

Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in mind that our Site may contain links to other sites not owned or controlled by us and we have no responsibility or liability whatsoever for the content, actions, or policies of third party websites. The inclusion of third party websites on our Site in no way constitutes an endorsement of the content, actions or policies of the websites of others. We encourage you to be aware when you leave our Site or applications and to read the privacy policies of other sites that may collect your personal information.  

9. Retention of Personal Information 

We retain personal information for as long as necessary to provide the Service and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. For example, we keep Class Recordings for up to twelve months after the date of the applicable Class. 

10. Cookie Policy 

What are cookies? 

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device. Cookies are used with web beacons and similar technologies. Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email and can read cookies they place on your device. 

What are cookies used for? 

Cookies and similar technologies allow a site or service to know if your computer or device has visited that site or service before. Cookies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. We and our analytics and advertising partners use cookies and other identifiers, such as IP address, and technologies on our Site to collect personal information (such as the pages you visit, the links you click on, and similar usage information) when you use our Site, including personal information about your online activities over time and across different websites or online services. We and our analytics and advertising partners may use cookies and similar technologies to provide targeted advertising. 

How to control and review cookies 

You can find out more about how to block cookies in specific browsers at http://aboutcookies.org. 

Website Performance Analysis 

Google Analytics: We use Google Analytics, which is provided by Google Inc. Google Analytics cookies help us improve our Site by providing us with aggregate statistics on how many users visit it, which parts of the site are viewed the most, the city or regional location of those users, device type and browser. These cookies do not identify you personally. Nevertheless, if you prefer to prevent Google from collecting data generated by cookies and relating to your use of the Site (including your IP address) as well as from processing this data by Google, you may do so by downloading and installing the Browser Add-on on https://tools.google.com/dlpage/gaoptout?hl=en 

Facebook Pixel: We use Facebook Pixel, which is provided by Facebook, Inc. Facebook Pixel cookies help us to measure the return on investment of Facebook Ads by reporting on the actions people take after viewing those ads. We create pixels that track conversions, add them to the pages of their website where the conversion will happen and then track these conversions to ads they are running on Facebook. No personal information is contained or collected as a result of using these cookies or pixels. If you want to opt out of Facebook Pixel cookies, please use the following link: https://optout.networkadvertising.org/?c=1  

Website Advertising 

Google Adwords: We use Google Adwords, which is provided by Google Inc. Google Adwords conversation tracking cookies help us to measure and optimize the performance and user experience related to our ads in Google Search or selected Google Display Network sites. These cookies do not identify you personally. Learn more about Google's privacy policy on https://policies.google.com/privacy?hl=en and for opt out visit https://www.google.com/settings/u/0/ads/authenticated?hl=en 

11. Changes to this Privacy Policy 

TJEP may modify or revise this Privacy Policy from time to time. TJEP will notify users of any changes to our Privacy Policy by posting the revised Privacy Policy with an updated date of revision on our Service. If we change this Policy in a material manner, we will do our best to notify you of the changes by posting a notice on our website. We recommend that you review the Privacy Policy each time you visit the Service to stay informed of our privacy practices. 

12. Contact TJEP 

Please contact TJEP with any questions or comments. 

By email: info@truvie.org 

By mail: 520 Eighth Avenue, 15th Floor, New York, NY 10018 

You may also wish to visit the TJEP Common Questions and Resources page, which hosts useful FAQs and information that you may find helpful. 

13. Children’s Privacy Notice 

This Children’s Privacy Notice supplements our Privacy Policy and provides additional information about how we collect, use and share personal information from children under the age of 13 (a “Child” or “Children”). 

TJEP is committed to Children’s privacy. 

Protecting the privacy of Children is especially important to TJEP. For that reason, we created certain features designed to help protect personal information relating to Children (“Child Users”). We seek the consent of a parent or legal guardian (“Parent”) before we collect any personal information directly from a Child User. For general tips about protecting Children’s online privacy, please visit the Federal Trade Commission’s resource concerning Protecting Your Child’s Privacy Online and the Office of the Privacy Commissioner of Canada’s resource concerning privacy and kids.

Collection: Truvie collects personal information about Child Users directly from Parents and, when we have verified parental consent of Parents, directly from Children. Child Users are expected to use and select children’s mode which we call Learner Space when they use our Service and must be in Learner Space to attend class. Child Users cannot enroll in classes through the Learner Space. We may allow Child Users to mark classes they like or want to attend, which Parents can see, but can only attend classes if their Parents enroll them. Parents provide us with the Child Users name and age. Parents may additionally provide us with descriptions of the type of schooling their Child attends, local time zone, and additional notes for the Teacher. In addition, Child Users may share information about themselves during online classes. The Truvie class sessions take place over online videos in which video images and audio of the Child Users are recorded. We may collect other personal information about Child Users in Learner Space, including passively collected data, as described in our general Privacy Policy, with the exception that we do not collect payment information from Child Users or allow third parties to use personal information collected through analytics cookies for their own purposes. We also do not condition participation in our Service for Child Users on the collection of more personal information than is reasonably necessary. 

Use and Disclosure: Once we obtain verified parental consent, we may use and share personal information collected from Child Users for many of the same purposes described in the general Privacy Policy. We recommend classes to Parents based on Child Users’ activities on our Site, such as when they mark classes or are enrolled in classes. We do not, however, send promotional emails to Child Users or allow third party analytics providers to collect personal information for their own uses through Learner Space. 

Truvie shares, or allows you to share, the name, age, postal address, local time zone, and any notes Parents have provided about their Child to the class Teacher to allow the Teacher to provide classes. Child Users’ video image and voice audio and potentially background images of their home and family members are shared with the Teacher and the rest of the Class as they participate in classes. Child Users may also share information about themselves with the Teacher and the rest of their class during the Class session voluntarily, including content, images, and videos they may upload and share with their class. While TJEP expects Teachers and all other Users to abide by our standards of conduct and we take reasonable steps to monitor certain communications and posts, please note that we are not able to control or monitor all personal information your Child may share with Teachers or other classmates, nor what those third parties ultimately do with that information. 

At times, we may allow Child Users and Parents to submit content, including photos and artwork, along with other information about the Child User (like age, first name or initials and city, state, and country) that you may allow us to display publicly. Parents should review Child User’s submissions and avoid uploading any private information about the Child User, family members, or others. TJEP is not responsible for what other third parties do with information you choose to share publicly. 

Some Teachers may ask Child Users and their Parents to use third party sites and services. Parents should review the privacy notices for those third party sites and services to understand their privacy practices. We are not responsible for nor do we systematically monitor those third party sites and services. 

Class Video Recordings: As described above, TJEP records video of Child Users and Teachers during Truvie classes (“Class Recordings”). The Class Recordings may be made available by TJEP to the Teacher of the class. 

Please note that in some cases, classes are taught by a “Teacher” that is actually an organization, group, or team of instructors (“Teacher Organization”). In such cases, Class Recordings may be accessed by the entire Teacher Organization, and access would not necessarily be limited to a single individual instructor. TJEP may also use Class Recordings to provide feedback to Teachers, for evaluation purposes, customer support, and for compliance purposes. 

TJEP will obtain additional parental consent before we use any Class Recordings for promotional or other purposes.  

Parental Consent: Truvie sends a direct notice with these privacy disclosures and obtains verifiable parental consent before collecting, using, and sharing personal information from your Child. TJEP requires that you provide your credit card information to verify you and to register your Child for and pay for a Truvie Class. If you do not consent or withdraw consent, then we will not collect, use, or disclose any (additional) personal information about your Child, and your Child will not be allowed to use the Service in any way.  

Parental Choices and Controls: At any time, you can review and refuse to permit us to collect further personal information from your Children in association with your account. You can also request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You may review and update certain of your Child’s information by logging onto your account. In your account, you can review topics of interest we have inferred based on your Child’s likes and past classes. You can choose to opt-out of recommendations based on your Child’s activities and instead choose the learning topics you want to hear about. You can contact Truvie to request access to, change, or delete your Child’s personal information, or revoke consent for our collection, use, and sharing of personal information, by sending an email to us at info@truvie.org. A valid request to delete personal information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal information collected from Child Users when it is no longer needed for the purpose for which it was collected. 

14. Regional information 

This Regional information notice supplements our Privacy Policy. In certain regions, you may have certain additional rights. This may include the right to request access or to update or review your information, request that it be deleted or anonymized, or object to or restrict TJEP using it for certain purposes.  If you wish to exercise a right, please Contact TJEP. Our ability to respond to specific requests may be limited by applicable law and the functionality of our Service. 

International Data Transfer: We are based in the United States. The information you submit to us and that we automatically collect as a result of your using the Services will be transferred to the United States, where the privacy and data protection rules may differ from those in your country. We may also share your personal information with recipients some of which will be located in countries other than where you are located including, the United States. If you are located in Europe, the regulators in your country may not consider the data protection rules in the United States and other countries outside of Europe to provide adequate protection for the personal information. However, where we make such transfers to third party recipients, we take steps to ensure they are made in compliance with applicable data protection rules including, as necessary entry into Standard Contractual Clauses or reliance on Binding Corporate Rules. You can obtain further information in relation to the international transfers and copies of the safeguards implemented by contacting info@truvie.org. 

California Minors' Rights: If you are a registered user under the age of 18 residing in California, you are entitled to request removal of content or information you have posted publicly on our Service. To request removal, please Contact TJEP for assistance. Please note that your request does not ensure complete or comprehensive removal, as the content or information may be retained subject to applicable law.