Effective Date: July 25, 2023
At Raeva, we value and prioritize your privacy, and we are dedicated to safeguarding your personal information. This Raeva’s Privacy Policy (“Privacy Policy”) outlines how we handle the information we collect about you when you access and use our website at www.raevaapp.com and the Raeva mobile app (the “Platform”). It also informs you about your privacy rights and the legal protections in place. This Privacy Policy describes the information we collect, how we collect it, why we collect it, how we protect it, as well as the rights you have over it.
References to “you,” “your,” or “user” under this Privacy Policy refers to anyone accessing the Platform and using its features – including if you are a guest, Teacher, or Customer. References to “we,” “us,” or “our” refers to Raeva, Inc (“Raeva”), the provider of the Platform.
1. Your acceptance of this Privacy Policy
We strongly encourage you to read this Privacy Policy in conjunction with our Terms of Use (and other applicable policies and agreements that apply when you use the Platform). By doing so, you will gain a comprehensive understanding of the types of information we collect from or about you and how we utilize it.
By accessing and using the Platform, including as a guest, Customer, or Teacher, you acknowledge that you have read this Privacy Policy and have agreed to how we handle your information. If you do not agree with how we handle your information, your only option is to refrain from using the Platform.
2. The information we collect from you
We collect personal and non-personal information on the Platform. We collect this information when you willingly give it to us via form submissions, we collect some automatically using technologies and third-party tools, and we collect some from third-party sources.
2.1 The information you give us
Depending on your use of the Platform, we collect both personal and non-personal information when you fill out forms on the Platform. This may include when you create a Teacher or Customer account, complete your profile, book and schedule a session, use the contact us form, subscribe to our newsletters, respond to our surveys, submit user-generated content (such as Teacher listings, user reviews, and feedback), and provide your payment method to purchase a Teacher service or receive earnings from sales.
The information you give to us may mostly contain personal information, including without limitation, your First and Last Name, Email Address, Phone Number, Social Media Profile(s), Profile Picture, Company/Business Details (for Teachers), Card and/or Bank Information, and Location.
Sensitive information: Some of the personal information you give to us (for example, your card and bank information) may be termed sensitive information according to certain privacy laws. Where we collect any sensitive information from you, we ensure additional protection and care are applied (for example, your card information is received and handled by Stripe, and they apply industry-standard methods of security. We do not store it on our database).
Are you obligated to provide personal information? It is completely within your discretion to decide whether to provide us with personal information. However, it is essential to note that we require your personal information to fulfill our contractual obligations to you. Failure to provide the necessary personal information may impede our ability to deliver the necessary features to you.
Location, gallery, and other device access: In some instances, we may seek your consent to access your precise location on the map to match users around you, or we may require you to grant us access to your device file manager or gallery to upload your user-generated contents. These actions are based on your consent, and you can withdraw your consent at any time.
2.2 The information we collect automatically
We and our third-party service providers use certain technologies (cookies, beacons, tags, pixels, etc.) and tools to gather certain personal and non-personal information when you access the Platform (this also applies if you are a guest user). The information we automatically collect is mostly non-personal, hashed information, and it may include the following:
Device properties: Including your device IP address, geolocation, and browser details.
Usage and analytics: Including anonymous number of page views, number of visitors, clicks, number of app downloads, redownloads, and total downloads, as well as user engagement metrics, active users, and number of installations and sessions.
Transaction: Including details about the service purchased, the amount, payment method used, users involved, and time and date of transaction.
Marketing: Including your preferences regarding receiving marketing communications from us and your communication preferences.
2.3 The information we collect from third parties
As referenced earlier, we obtain some information from third-party sources, including analytics providers, app distributors, social media networks, and network advertisers. For example, Our app distributors (Google and Apple) and website host (WordPress) provide us with analytics and usage information about the Platform.
3. Purposes for collecting your information
We will only process your personal information in accordance with applicable legal requirements. Our collection and use of your information depends on the information collected.
We may collect, use, store, and process the information we collect for the following purposes:
To identify you, verify your account, grant you access to certain features on the Platform, enable your interaction with other users, and host your content.
To enable two-way communication between you and us, including responding to your inquiries, sending you marketing messages (when you subscribe), and notifying you of activities related to your account.
To process your payments for a service (for Customers) or enable the withdrawal of your earnings (for Teachers).
To upload your content from your device to the Platform at your request.
To match Customers with services from Teachers that are close to their location.
To perform our legal obligations, including where we are required to report tax earnings, comply with applicable laws, keep records, and respond to lawful requests from the government.
To gather analytics and identify where we need to improve for marketing purposes.
To monitor fraudulent practices and other violations of our Terms of Use and any applicable laws.
To understand your use of the Platform and improve your user experience through tailored contents.
4. Disclosures of your information
We do not engage in practices termed as “a sale for monetary consideration.” This means that we do not sell or license your information to third parties for them to market their products and services to you. We do not disclose your information to third parties except under the following circumstances:
4.1 Information shared between users and the public: We will share your information with another user if you both enter into an agreement to teach or learn from each other. Likewise, if you upload user-generated content on the Platform (for example, a Teacher submits content for their service), other users and visitors may access your profile picture and any personal information contained in your content. Likewise, users may interact with one another via chats and comments, and any personal information shared by each user will be available to the other users in the same space.
4.2 Information shared with third-party service providers: We work with third parties that provide certain features on our behalf. This may include, without limitation, website hosting, app distribution, analytics gathering, marketing, payment processing, and Platform security. These third parties may require access to your information to perform their services (for example, the card information you share with us is needed by Stripe to enable them to process your payments). However, these third parties are bound by agreements to keep your information confidential and restricted to the purposes for which we collect it.
4.3 Information shared under a legal request or for the protection of rights: At the request of competent authorities, we will have no choice but to share information about you (for example, to meet national security, respond to a court order, or other legal summonses). We may also share personal information with public and private entities in the event that such disclosure is necessary to protect our rights or the rights of other users or third parties.
4.4 Information shared during a business transfer transaction: We may share information with third-party entities if we engage in any business transaction that involves the transfer of ownership. This may include a sale of assets, a merger, a consolidation, or a case of bankruptcy.
4.5 Information shared at your request: If you instruct us to share any personal information with an individual or entity, we may have no option but to comply with your request.
5. Cookies and similar tracking technologies
5.1 Introduction: When you access the Platform or use certain features, cookies may be embedded on your device browser to enable us to perform certain tasks. At the moment, we do not directly set cookies on the Platform, they are set by third-party service providers who perform tasks on our behalf. For example, WordPress and Google set cookies to enable them to gather usage and analytics on our behalf.
5.2 Your consent to cookies: When you first visit the Platform, you will be prompted to accept or reject cookies. By accepting, you agree to how we use cookies.
5.3 What cookies are: Cookies are tiny code that website owners embed on users’ devices (smartphone, tablet, or computer) to enable them to perform certain tasks, such as tracking user behaviors for personalization, securing the website, enabling certain functions, identifying users, and hosting content.
5.4 Why we use cookies: With respect to the Platform, third parties set cookies on your browser or device to remember your preferences and inputs, secure the website, gather usage and analytics for content tailoring, monitor violations, process payments, deliver targeted adverts, and host user content.
5.5 Duration of cookies: Cookies’ durations are dependent on whether they are “session” or “persistent.” Session cookies are those types of cookies that are designed to expire when the user closes their browser. This means that they are automatically deleted when the user ends a browsing session. Persistent cookies, on the other hand, do not expire after a browsing session. They have defined expiry dates, which range from minutes to years.
5.6 How to control cookies: Most browsers allow you to control cookies via the privacy section under settings. You can choose the types of cookies you want to allow on your device. However, be aware that if you delete certain cookies, specifically the functional or necessary cookies, your browsing experience may be affected.
6. Third-party tracking tools
Some of the third-party tracking tools we use include Google Analytics and Firebase, which are Application Programming Interfaces (APIs) provided by Google for analytics purposes. These tools anonymously track user movements on the Platform, which helps us to personalize the Platform and identify where improvements are needed. However, you can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Add-on on your device browser.
7. Our marketing practices
We use the information you provide and those collected automatically to market the Platform and its features to you. Our marketing practices include:
2.1 Push notifications marketing: We may seek your consent to send you marketing messages via app push notifications. When you agree to receive push marketing messages from us, we will send occasional messages about features and stuff that we think match your interest. This practice is strictly based on your consent, and you can withdraw your consent at any time by using the settings area of your device.
2.2 Email newsletters: If you consent to receive newsletters from us to your email address, we will send marketing emails to your email address about offers about deals that we think match your preference. This practice is strictly based on your consent, and you can always opt out by clicking the opt-out (unsubscribe) button at the bottom of any email we send to your email address.
2.3 Interest-based advertising: We work with network advertisers, such as Facebook and Instagram, who help us to advertise the Platform on their platforms. These third parties deploy their own cookies and other tracking technologies on the Platform, and they gather anonymous or hashed information about your interests across the Platform and other services (we also share the information we gather through analytics with them), then they use the information to target you on their Platforms. However, you can stop these third parties from tracking your preferences and interest to target you with adverts. To opt out of interest-based advertising, please visit this link: http://optout.aboutads.info/
8. Information security
We have implemented comprehensive security measures to prevent accidental loss, unauthorized access, alteration, or disclosure of your personal information. Furthermore, we restrict access to your personal information to only those employees, agents, contractors, and other third parties who require it for legitimate business purposes. These individuals will process your personal information solely based on our instructions and are bound by confidentiality obligations.
We have established protocols to address any suspected breaches of personal information. In the event of a data breach where we are legally obligated to do so, we will promptly notify you and the appropriate regulatory authorities in accordance with our legal obligations.
However, the transmission and security of personal information in the digital space is not 100% proven to be secure. Therefore, we do not guarantee that third parties will not have unauthorized access to your personal information.
9. How long we retain your information
We will retain your personal information only for as long as reasonably necessary to fulfill the purposes for which we collected it, including meeting any legal, regulatory, tax, accounting, or reporting obligations. In certain circumstances, such as in the case of a complaint or if there is a reasonable likelihood of litigation arising from our relationship with you, we may retain your personal information for a longer period. In the absence of the foregoing, we delete your information upon your request to delete it from our database.
To determine the appropriate retention period for personal information, we take into account the quantity, nature, and sensitivity of the personal information, the potential risk of unauthorized use or disclosure of the information, the purposes for which we process the information, whether we can achieve those purposes through alternative means, and the applicable legal, regulatory, tax, accounting, or other requirements.
10. Your rights and choices
Right to access and edit your information: You may access and edit your information at any time. Users can use the Edit Profile function under the settings section of their profile to edit their name, phone number, and similar information. Additionally, Teachers can use the Payout Account function under settings to edit their payout information.
Right to delete your information: You may request that we delete your personal information and account by using the Delete account function under settings. Please, note that the deletion of your information is subject to certain conditions, including if you have pending claims or obligations to settle. Even after you request for deletion, we may also retain certain information about you in backup for continuity or to comply with our legal obligations.
Right to withdraw your consent: If the handling of any of your personal information is based on consent (for example, push notifications and email newsletters subscriptions), you can withdraw your consent at any time.
Right to reporting: If you believe that we are unlawfully handling your personal information or not as described under this Privacy Policy, you can complain to us about it by contacting us. If you are unsatisfied with our response, you can report us to any privacy authority in your location.
11. California users
If you are a Customer or Teacher using the Platform as a California resident, this section applies to you in addition to the entirety of this Privacy Policy. This section details the rights and choices provided by the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).
Please, note that Raeva is not in the business of selling or licensing personal information, such as your name, email address, and phone number to third parties for them to market their services or products to you. We may only share aggregated and hashed analytics information with third parties to market the Platform, which is not termed a “sale” under applicable laws.
Also, your web browser may have a Do Not Track (DNT) feature, which when enabled, sends a notice to us to not track your online activity and behavior. Currently, Raeva does not respond to DNT signals, as there is no universally accepted consensus among industry participants.
In addition to the other rights you have under this Privacy Policy, you have the additional rights below:
The right to request information about the categories of personal information we have collected about you in the past 12 calendar months, including the sources from which we obtained this information, the reasons for the collection, and the third parties we have shared them with.
The right to request that we delete the personal information we hold about you, subject to certain exceptions.
The right to opt out of the sale of your personal information to third parties for their direct marketing purposes. As mentioned earlier, Raeva does sell or license personal information to third parties for monetary consideration.
You have the right to non-discrimination if you request to exercise any of your rights under this section.
You have the right to request that we limit your card and/or bank information strictly for the purpose of processing your payments and payouts (where applicable). Fortunately, we do not use your information for anything else other than to process your session bookings and Teacher payouts.
You can exercise any of your rights under this section by reaching out to us at [email protected] or using the contact us or support section of the Platform. We may need to verify your identity before processing your request.
You or any agent you designate may make these requests. If it involves the deletion of your personal information, we may verify you to further before we approve it. This is to ascertain that the person who provided personal information to us or their agent is making the request.
12. Rights of Users in Nevada
Users in Nevada have the right to request that we opt them out of the sale of their personal information to third parties for monetary consideration and for the third parties to sell it to additional third parties. As mentioned, Raeva does not engage in the sale of personal information to third parties for monetary consideration. However, Nevada users can still opt out of any future sale of their personal information by reaching out to us at [email protected].
13. Children policy
Please note that the Platform is not intended for use by children (people under 18 years of age), and we do not knowingly collect personal information from children. If you are between 13 years of age and 17, you can only use the Platform provided that you can demonstrate you have obtained consent from at least a parent or legal guardian.
14. Third-party links
The Platform may contain links to third-party websites, plug-ins, and applications. By clicking on these links or enabling the connections, you may allow third parties to collect or share information about you. Please note that we do not have control over these third-party websites and their privacy practices. Therefore, we cannot be held responsible for their privacy statements and how they handle your information on their platforms. We strongly advise that when you leave the Platform, you take the time to read the privacy policies of each website you visit.
15. Contacting Us
If you have any questions or concerns regarding this Privacy Policy, please contact us at [email protected]. We will make every effort to address your inquiries in a timely and satisfactory manner.