PRIVACY POLICY – OXFORD LEARNING CENTRES HEAD OFFICE

1. Who We Are

We are Oxford Learning Centres, Inc. (referred to herein as “Oxford Learning,” “we,” “us,” or “our”).

2. Purpose of This Privacy Policy

We provide supplemental education and assessment services, including but not limited to online tutoring services accessed through the Site (the “Services”). This Privacy Policy explains how we handle your and your child’s Personal Information, including how we collect it, use it, and share it with others, in the course or fulfilling our obligations to you. Having reviewed this Privacy Policy, or having been given the opportunity to do so, you expressly consent to the terms and conditions of this Privacy Policy. If you have questions, comments or concerns about our Privacy Policy, please contact us at privacy@oxfordlearning.com.

3. If You Elect Not to Provide Personal Information

You may choose not to provide us with your Personal Information. However, if you choose not to provide your Personal Information, you will not be able to access and receive the Services.

4. What is Personal Information?

Personal Information includes: your name, address, telephone number, email address, credit card information, postal/zip code, town or city, and gender; click through activity, product preferences or instructions; information about your computer and about your visits to and use of this website, such as your IP address, geographical location, browser type, operating system, referral source, length of visit and number of page views; information that you provide to us for the purpose of registering with us (including your name, email address, telephone number, postal address, and your child’s details); information relating to any transactions carried out between you and us, including information relating to any purchases you make; information that you provide to us for the purpose of obtaining the Services, health and financial information, email notifications and/or newsletters; audio and/or video files recorded during tutoring sessions; and, any other information that you choose to send to us.

5. Why We Collect Personal Information

We collect Personal Information in order to facilitate the Services, including: completing your purchase, establishing and verifying your identity, activating and maintaining your account, providing the services, offering updates, communicating with you about products and services, and fulfillment and processing of transactions.

We may also put Personal Information to other uses, which may include communicating information and offers to you; responding to your questions, inquiries, comments and instructions; to better understand, analyze, and respond to your needs and preferences; for our business management purposes; processing payments and the Services ordered; and to subsequently develop, enhance, and/or provide products and services to meet those needs and preferences.

Your Personal Information may also be used by us to contact you regarding other products or services which may be of interest to you, and for our customer appreciation programs.

Your Personal Information may be passed on to a third party in the event of a transfer of ownership or assets, or a bankruptcy, of Oxford Learning or any of its affiliates or distributors. Oxford Learning or any of its affiliates or distributors may also disclose your Personal Information to one or more of their respective subsidiary, parent companies, and/or franchisors. However, all of the parent, subsidiary, franchisor, and affiliated legal entities and businesses of Oxford Learning that receive your Personal Information will comply with the terms of this Privacy Policy with respect to their use and disclosure of such Personal Information.

Oxford Learning assumes no responsibility or liability for the privacy practices of our third-party suppliers in their handling of your Personal Information they collect from you online or offline.

We will not sell your personal information to anyone.

6. How We Collect Personal Information

(a) When you register for an account or interact with our Services

We collect Personal Information when you access a Site or seek to access the Services, including when you register with us. We use this Personal Information to create your account, enable your activity within our Services, manage your account, process transactions, and to provide the Services generally, including to develop, enhance, and improve our Services and your experience. We also use this data for internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.

(b) When you communicate with us or sign up for promotional materials

We collect Personal Information when you communicate with us or sign up to receive promotional materials or information via email, push notifications, or text messages – including email address, mobile number, etc.

If you consent to such messages, we may use your Personal Information and other information to communicate with you to provide you with promotional messages and personalized advertising; to notify you of other products; to notify you of contests or promotions; to notify you of Services we think may be of interest to you; and, for other marketing purposes.

We may use your Personal Information to respond to your requests for online services, or to any other communication you initiate. We may also use your Personal Information to address your requests, enquiries, and complaints.

7. Sharing of Personal Information

Your Personal Information has been collected by us in connection with purchases made by you of the products or Services, and for the other uses described in the Why We Collect Personal Information section above. By providing your Personal Information to us, you are consenting to our sharing that information as described in this Privacy Policy.

We will not otherwise share your Personal Information, except: to third parties performing functions on our behalf (such as analyzing data, providing marketing assistance, providing search results and links, processing credit card and other payments, hosting, providing, maintaining or operating the Services, processing transactions, and providing customer service); where we are required by law to disclose Personal Information; in connection with any legal proceedings or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention, identity verification, and reducing credit risk); and, to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling, we will require any person or entity to whom we provide your Personal Information to agree to comply with our then-current Privacy Policy. We will take reasonable commercial efforts to ensure that they comply with our Privacy Policy, however we will have no liability to you if any such person or entity fails to do so.

8. Consent

We try to ensure that you understand how we use your Personal Information. One of the ways this is done is by obtaining your consent. Consent may be either express or implied. Express consent is given when we specifically ask you if it is acceptable to you that we gather certain information and you explicitly agree that it is. Implied consent occurs when you provide information that may be Personal Information without objection. As we obtain only the information necessary to assist you with the transaction you require, we operate under the understanding that you have agreed to provide us with this Personal Information voluntarily and with knowledge of this Policy whenever you do so.

9. Cookies and Device Identifiers

This Site uses “cookies” and device identifiers to help personalise your online experience with us. A cookie is a small text file that is stored on your computer to help us make your visit to our site more “user-friendly”. Cookies provide us with information about your use of the Site that can help us improve the Site and your experience with it. Any Personal Information collected about you through cookies will be treated in accordance with this Privacy Policy. If you have set your browser to warn you before accepting cookies, you should receive a warning message with each cookie. You may refuse cookies by turning them off in your browser, however you should be aware that our site, like most other popular sites, may not work well with “cookies disabled.” A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyze and improve the performance of the Site and the Services.

10. Site Usage Information

Like most websites, this Site gathers traffic patterns, site usage information and other aggregated data in order to evaluate our visitors’ preferences and the effectiveness of our Site. This aggregate usage data does not identify you individually. We may share anonymous, aggregated statistics about visitors to our Site with others outside our company, or we may allow third-parties to collect aggregate data through our Site.

11. Access

We will advise you on request about what Personal Information about you that we have collected. If you provide a written or email request for this information, we will act upon this request within 30 days and may charge a reasonable cost (e.g. photocopying and mail charges) to the individual making the request. You may be required to provide sufficient proof of your identity at this time to ensure the safety and security of the Personal Information we hold and that it is provided to individuals in accordance with this Policy. We reserve the right to decline to provide access to Personal Information where the information requested: would disclose Personal Information of another individual or of a deceased individual; is subject to legal privilege; is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information; does not exist, is not held, or cannot be found by us; could reasonably result in serious emotional harm to the individual or another individual, or serious bodily harm to another individual; or, may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions. We will not respond to repetitious or vexatious requests for access.

12. Updating or Correcting Your Information

You may in most cases correct or update your Personal Information by instructing us to do so on your behalf.

You represent and warrant that all Personal Information you provide us is true and correct.

13. Your California Privacy Rights

Under California law, California residents may opt-out of Oxford Learning disclosing their Personal Information to third parties for their marketing purposes. If you are a California resident and do not want Oxford Learning to disclose your Personal Information to third parties for their marketing purposes, please contact us at privacy@gradepowerlearning.com or writing to us at Suite 230-747 Hyde Park Road, London, Ontario, N6H 3S3 Attention: Chief Privacy Officer and we will respond within 30 days.

14. Security and Retention

We operate secure data networks protected by industry-standard password protected systems, and maintain physical, encryption, electronic and procedural safeguards to guard the integrity and privacy of these systems and of your Personal Information. Although we cannot guarantee that there will never be a security problem, we and our agents that have access to your information carefully guard against the loss, misuse or alteration of the information we collect.

We will retain your Personal Information for as long as needed to provide Services to you. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

15. Our Policy Regarding Children

The Site is not intended for use by children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13. The Children’s Online Privacy Protection Act (COPPA) and the Personal Information and Protection of Electronic Documents Act (PIPEDA) each govern information gathering online from or about children under the age of 13 in the United States and Canada, respectively. Verifiable consent from a child’s parent or guardian is required before collecting, using, or disclosing Personal Information from a child under the age of 13.

Our Site collects no information about children under the age of 13 unless their parent or legal guardian chooses to provide information to us. When the Site needs to collect information about a child under 13 years old, COPPA/PIPEDA required information and instructions will be provided by the specific web page that collects information about the child to the parent or legal guardian. The web page will specify exactly what the information will be used for, who will see it, and how long it will be kept.

If a parent or legal guardian becomes aware that their child has provided us with Personal Information without the parent or legal guardian’s consent, please contact us at privacy@oxfordlearning.com or writing to us at Suite 230-747 Hyde Park Road, London, Ontario, N6H 3S3 Attention: Chief Privacy Officer.

16. Marketing Communications

Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials or information (referred to as “Commercial Electronic Messages, or “CEM”s). You may revoke your consent to the receipt of CEMs at any time. This will not affect the processing of your Personal Information in relation to any Services ordered by you.

17. Changes to this Privacy Policy

In order to enhance our Services, it might be necessary to change this Privacy Policy from time to time. We therefore reserve the right to modify this Privacy Policy in accordance with the applicable data protection laws. Please visit our Website from time to time for information on updates to this Privacy Policy.

18. Governing Law

Our online privacy practices are governed by the laws of Canada and Ontario, which may differ from privacy laws in your province, state or home country. By submitting your Personal Information to this Site, you consent to the transfer of your Personal Information to our Affiliates in Canada or the United States and our use and disclosure in accordance with the laws of Canada and Ontario and with this Privacy Policy.

19. For More Information or Assistance

If you have any questions regarding this Privacy Policy or the privacy practices of Oxford Learning or its affiliates, or if you require assistance to withdraw your consent to our processing of your

Personal Information or wish to request that your Personal Information be deleted, please contact us by sending an email to privacy@oxfordlearning.com or writing to us at Suite 230-747 Hyde Park Road, London, Ontario, N6H 3S3 Attention: Chief Privacy Officer.

This Privacy Policy is effective as of April 14, 2020

Our Privacy Policy has been updated to meet new regulations. Please read it here.