VIRTU.ACADEMY PRIVACY POLICY

 
 

Effective Date: July 3, 2019

Virtu.Academy, LLC. (“Virtu.Academy” “us” or “we”) collects, transmits, and stores information about our Users.  The term “you” or “You” or “User” or “Users” shall refer to Students, Teachers, Educators or any person or entity who views, uses, accesses, browses or submits any content or material to the Service (defined below).  Providing your information is voluntary and your use of the Service (defined below) after the effective date of this document constitutes your acceptance of this Privacy Policy.  If you do not agree to all the terms and conditions of this Privacy Policy, do not use the Service.

COLLECTING INFORMATION ON PERSONS UNDER 16 AND FERPA COMPLIANCE

The Children’s Online Privacy and Protection Act (COPPA) prohibits certain companies from collecting data from children under thirteen years of age.  Since other jurisdictions place similar restrictions on children under 16 years of age, we will never knowingly solicit, nor will we accept, personally identifiable information from users under sixteen (16) years of age without parental or guardian consent.  We take steps to verify age through the use of a credit card or PayPal account, and if the Student is under 16 years of age, we require the parent or guardian to set up the account and give consent.  If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at hello@virtu.academy.  If we become aware that a child under 16 has provided us with Personal Information, we will take steps to delete such information from our files.

To the extent that we work with, coordinate or share data with educational institutions and educators that fall under the Family Educational Rights and Privacy Act of 1974 (“Educators”) we enter into arrangements with those Educators to ensure that data is protected in compliance with the law by requiring them to adhere to our FERPA Notice terms.

INFORMATION WE COLLECT

This Privacy Policy applies only to information we collect via the website Virtu.Academy (“Site”), and online applications (“Apps”) (the Site and Apps collectively referred to as, the (“Service”).  In order to help you get the most out of our service, we collect User submitted personally identifiable information, namely information that relates to an identifiable person (“PII”) when you use the Service.  We have four kinds of Users for the Service:  “Visitors” are people who visit our Site and want more information about our Service, “Students” are Users that wish to purchase music lessons through our Service either directly or through their parents/guardians.  “Teachers” are instructors who offer lessons to Students through our Service.  “Educators” are staff and teachers from K-12 or colleges that fall under FERPA and which may collect information on Students attendance and performance in connection with their authorized purposes in relation to maintaining education records of the Students enrolled at their institution.

For all Users accessing our site, we log their use and what pages they visit in connection with their browser.  If they are registered as a Student, Teacher or Educator, we will log their activities in connection with their use of the Service.  We also gather non-PII when you use the Service, including type of browser you use, access time, pages viewed, operating system of your computer or device, and mobile network information.  PII we collect may include your IP Address, unique device identifier, mobile network and geolocation.

Students.  For Students we collect the Student’s name, address, contact information, user name and password.  We also will collect payment information such as a credit card number of the Student or their parent/guardian to be stored with our payments processors, Stripe and PayPal.  We will also keep track of Students’ use of the Services and lessons.  If the Student is associated with a particular educational institution we may collect the name of your school, grade and classroom instructor.  We also collect any feedback to us or regarding Teachers that you post.

Teachers.  For Teachers, we collect the Teacher’s name address, calendar, contact information, user name and password, as well as any photos or other information provided with respect to the services they wish to offer.  We also may collect your bank or credit card information to ensure you get compensated for teaching, your Federal Tax ID Number, date of birth or other information for tax reporting purposes and to conduct sex offender background checks.  We don’t store payment information PII, it is stored with our payments providers, Stripe and PayPal.

Educators.  For Educators we collect the names, contact information, institution name and the class or grade represented.

Use of Cookies

Virtu.Academy uses cookies to help create a better user experience.  A cookie is a small text file that is sent to your browser from a web server and may be stored on your computer’s hard drive.  Virtu.Academy uses cookies to better customize your experience on the Site based on User attributes like your location and account preferences.  No PII is stored in our cookies.  While you may elect to disable or delete cookies from your browser at any time, please note that this action may limit your use of Virtu.Academy services that require cookies.

If you are interested in more information about targeted advertising and how you control cookies from being put on your computer to deliver targeted advertising, you may visit the Network Advertising Initiative’s website http://www.networkadvertising.org/ and/or the Digital Advertising Alliance’s website http://www.aboutads.info/choices/.  You also can control advertising cookies from Google, by using its Ads Preference Manager.  Please note that to the extent advertising technology is integrated into the Site, you may still receive advertisements even if you opt-out of targeted advertising

HOW WE USE YOUR INFORMATION

We use PII, information from logs and non-PII as necessary to provide the service to you and to help you find, schedule and pay for lessons using the Service.

We also use PII, cookies, information from logs and non-PII for the purpose of improving the Service and your customer experience.

If Students share any PII in connection with Educators we will only use such Student PII in connection with a legitimate educational purpose and in compliance with FERPA unless the Student or their parent/guardian provides consent to do otherwise.  For all other Students (with parental/guardian consent where required by law), we will inform you of Services that may be of interest to you.

For Teachers, we will also use such PII as is necessary to conduct sex offender background checks.  We will only use such information in connection with determining your eligibility to offer your services on the Site and Services.

We also may de-identify to create aggregate statistical information to improve our Services and market the Service.

WHO WE SHARE YOUR INFORMATION WITH

We will not sell, rent, or share PII with third parties outside of our company without your consent, except in the following ways:

To Facilitate the Service.

We share Teacher and Student information between each other to arrange the lessons purchased on the Service, complete the transactions and if arranging the lessons on behalf of Educators, confirm that the lessons have been completed by sharing in each case the names, contact information, appointment dates/times and noting the date/time of completion.  We also share feedback that you post.

Law Enforcement and Internal Operations

PII may be provided where we are required to do so by law, or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against Virtu.Academy or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (iv) to protect the rights, property or safety of Virtu.Academy, its users or members of the general public.  We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law.  However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to any third party request to compel disclosure of your information.

Business Transfer

Virtu.Academy may sell, transfer or otherwise share some or all of its assets, including your PII, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.  Under such circumstances, Virtu.Academy will use commercially reasonable efforts to notify its users if their personal information is to be disclosed or transferred and/or becomes subject to a different privacy policy.

Third Parties

We sometimes contract with other companies and individuals to perform functions or services on our behalf, such as software maintenance, data hosting, sending email messages, etc.  We necessarily have to share such PII as necessary to provide and manage the Service.

Your Choices.

If you would like to stop receiving promotional information on services from us, you may remove yourself by following the instructions at the bottom of the email.

If you are in the European Economic Area (EEA), you have the right to access the information we have about you, as well as the right to request that we correct it, complete it, erase it, stop using it for certain purposes, or transfer certain information to you.  To make any such request, please contact us at hello@virtu.academy.  In order to protect your privacy, we may take steps to verify your identity when we receive your request.

To access or change your PII, log into your account and you can review and update your information.  To request access to any PII you are unable to access yourself, please contact us at hello@virtu.academy.  In order to protect your privacy, we may take steps to verify your identity before sharing PII with you.

To delete your account, send an email to hello@virtu.academy with the account holder’s name, email address, and phone number requesting that your account be deleted.  The account will generally be deleted from Virtu.Academy’s site within 14 business days.  If you delete your account we can no longer provide access to parts of the Service to you.  We may retain PII or payment information as required by law or for record keeping to defend legal claims.

Stripe and Payments Processing.  We utilize Stripe and PayPal as payment gateways for payments.  Data Processing takes place in the United States and Stripe and PayPal are each self-certified under the EU-U.S. and Swiss-US Privacy Shield.  Users should review Stripe’s Security Policy or PayPal’s Privacy Statement before initiating transactions on the Site.

HOW WE PROTECT YOUR INFORMATION

We have implemented reasonable administrative, technical and physical security measures to protect your personal information under our control against unauthorized access, destruction or alteration.  For example:

  • SSL encryption (https) everywhere where we deal with PII.

  • Password protection on your account.

  • Hashing of passwords.

  • Data is kept on secure, encrypted servers, located in the US.

  • Restricting staff access to PII protected by password logs and two factor authentication.

  • Regular staff privacy and security training.

  • Tokenization of payments, customer ID, and payment information by payment providers.

However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we store, process or transmit.

Payments Encryption:  Virtu.Academy utilizes only PCI-DSS compliant third party payment processors to ensure the security of your personal information through Stripe and PayPal.

PROCESSING IN THE UNITED STATES

The Service is operated in the United States of America.  Information we collect from you will be processed in the United States.  The laws of the United States may not protect the privacy of your information at the same level as provided by the laws of your country.  In an effort to safeguard individual privacy, we enter into agreements using standard contract clauses, approved by the European Commission, with our service providers and Affiliates that transfer Personal Information to the United States.  You will not lose any rights or choices you have about the use of your Personal Information when it is transferred to the United States.

THIRD PARTY WEBSITES

We may link to other websites.  When you click on one of these links, you are ‘clicking’ to another website.  Virtu.Academy does not control the data collection or privacy practices of such third party sites.  We encourage you to read the privacy policies of any third party sites, as their collection, use and storage practices and policies may differ from ours.

NOTICE ABOUT “DO NOT TRACK”

“Do Not Track” or DNT is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking.  At present, our Site does not respond to or alter its practices when a DNT signal is received.

YOUR CALIFORNIA PRIVACY RIGHTS

California residents who have an established business relationship with Us may make a written request to Virtu.Academy about whether Virtu.Academy has disclosed any PII to any third parties for the third parties' direct marketing purposes during the prior calendar year.  To make such a request, please send an email or write us: hello@virtu.academy

Virtu.Academy

940 Tuxedo Blvd.

St. Louis, Missouri 63119

CHANGES TO PRIVACY POLICY

Virtu.Academy reserves the right to amend this Privacy Policy at any time.  If Virtu.Academy makes material changes to its Privacy Policy, we will notify you by changing the Effective Date on our Privacy Policy.  We may provide additional notification either via email, posting to our homepage or other means as we may deem commercially reasonable.

Questions?

If you ever have any questions about our online Privacy Policy, please contact us.  We respect your rights and privacy and will be happy to answer any questions or concerns you might have.  You may direct any such questions to us via email at:  hello@virtu.academy