Privacy Policy

Last Updated: November 18, 2024

The Off2Class.com website, including all associated software, code, algorithms, protocols, text, graphics, content, layouts, designs and interfaces (collectively, the “Site”) is owned by Global Online Language Services Inc. doing business as “Off2Class” (“Off2Class”, “we”, “us”, “ our”). We value the privacy of all those who access the Site. This privacy policy (“Privacy Policy”) explains the information we collect, use and disclose when you use the Site and provides our contact details should you have any questions about your privacy while using the Site. It should be read in conjunction with our Website Terms and Conditions of Use (the “Terms”). Capitalized terms that are not defined in this Privacy Policy have the meanings given to them in the Terms. By using this Site, you consent to this Privacy Policy.

Contact Information and Data Protection Officer

Off2Class is headquartered in Ontario, Canada. Off2Class has appointed an internal data protection officer for you to contact if you have any questions or concerns about Off2Class’ personal data policies or practices, which you can contact at privacy@off2class.com. Off2Class’ Data Protection Officer’s name and contact information are as follows:

What information do we collect?

For the purposes of this Privacy Policy:

“Personal Information” is information about an identifiable individual. Personal Information includes but is not limited to your name, residential address, residential telephone number and personal e-mail address.
“Business Contact Information” is your name, position name or title, company, work address, work email address and work telephone number. Business Contact Information generally does not constitute Personal Information.
“De-identified Information” means information (including Personal Information) that has been aggregated, anonymized and de-identified, so that it cannot (directly or indirectly) be used, alone or in combination with other data within our possession or control, to identify an individual.

We collect information from Customers (i.e., school boards or administrators, teachers or tutors) when you request and activate a Subscription Account or Free Account on the Site (an “Account”). No Personal Information is required for Customers to use the Site (e.g. you can use an anonymous email address and username to use the Site, without any loss in Site functionality). However, we understand that some Customers will use personally identifiable email addresses and usernames to use the Site, which will constitute Personal Information. We take this responsibility seriously and use this Personal Information only to deliver our Services to you.

When registering an Account, the Customer may be asked to enter your Business Contact Information (i.e., your name, work e-mail address or work address).

If you use our Contact feature, we collect information you provide to us, and use this information to respond to your request or comment. If you send us emails or letters, we may collect such information in a file specific to you.

When the Customer (or a teacher where he/she is the Authorized Person of a school board or school administrator) is using the Student Management System on the Site, the names, email addresses or mailing addresses of your students with whom you intend to use this Site may also be entered. Such information may only be provided as follows:

You must receive consent directly from all students over the age of 19 in order to enter any of their Personal Information on the Site. Alternatively, non-personally identifiable information (for example, non-identifiable usernames and email addresses that do not divulge the identity of students) may be used.
For all students ages 19 or younger, we recommend that you enter only non-personally identifiable information (for example, non-identifiable usernames and email addresses that do not divulge the identity of students). Alternatively, you must obtain consent from either the parents or guardians of such students or from the school administrator (in the U.S., where applicable) or, in jurisdictions where the age of consent is lower, from the students directly in order to enter any Personal Information on the Site.

IMPORTANT: By entering a third party’s Personal Information into this Site (such as a student who you intend to use this Site with), you represent and warrant that you have the appropriate authority and consent to enter that Personal Information into the Site and that we are entitled to collect, use and disclose that Personal Information as set out in this Privacy Policy, in reliance of such representation and warranty.

Please note that Customers who wish to use the Site without entering student email addresses, for example, because student email addresses may contain personally identifiable information, may be able to use a Single Sign-On (SSO) protocol to access the Site which may forgo the need to enter student email addresses into the Site. Please contact your Off2Class Product Specialist or Customer Success Manager to learn about SSO options at Off2Class.

We do not knowingly collect Personal Information other than as set out above. We do not collect, and we ask you to not share with us, any Personal Information related to:

Race or ethnic origin
Political opinions
Religious or philosophical beliefs
Trade union memberships
Genetic or biometric data
Health or mortality
Sex life or sexual orientation

We do not use Personal Information to make automated decisions about individuals.

Customers (or teachers where they are the Authorized Persons) should instruct students not to inadvertently enter Personal Information on the Site (for example, when answering a free text or essay-type homework question).

When you visit our Site, we may collect information about your visit through cookies and similar technologies (see our section Cookies and Other Tracking Technologies for more information).

What do we use your information for?

Any of the Personal Information we collect from you may be used in one of the following ways:

to facilitate the creation of and secure your Account;
identify you as a user in our system;
to process transactions you have initiated;
to provide you with the Services you request;
to administer a contest, promotion, survey or other Site feature that you have chosen to participate in;
to conduct internal research and develop our products and services; or
to send you periodic emails with information directly relevant to your use of the Service or to other Off2Class Services which may be of interest to you.

We may also use the Personal Information we collect to meet legal, regulatory, insurance, security and processing requirements, and otherwise with your consent, or as permitted or required by law.

Your Personal Information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the Service.

Do we disclose your information to outside parties?

We do not sell, trade, or otherwise transfer to outside parties your Personal Information. Trusted third party service providers who assist us in operating the Service, conducting our business, or servicing you, may have access to your Personal Information, provided those parties agree to keep this information confidential and abide by this Privacy Policy.

The Site uses Hubspot to provide customer support and email messaging services to users of the Site. These are required to deliver the Site’s Service to you. You can review Hubspot’s privacy policy here (please note we do not knowingly share student information with Hubspot as we do not provide customer support directly to students).

The Site uses MailChimp to provide transactional email notification services (e.g. ‘homework is due’ notifications) to users of the Site. These are required to deliver the Site’s Service to you. You can review MailChimp’s privacy policy here.

The Site uses Google Analytics as our third-party analytics provider, as described above, information is not personally identifiable and is only used on an aggregate basis to deliver the Site’s Service to you. You can review Google Analytics’ privacy policy here.

The Site uses Stripe to process credit card payments to users of the Site that choose to purchase a subscription via credit card. Students cannot purchase subscriptions to the Site via credit card. You can review Stripe’s privacy policy here.

We may transfer your Personal Information as an asset in connection with any contemplated or actual sale, merger or other disposal of all or part of our business or assets, or as part of a corporate reorganization or other change in corporate control, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In such circumstances, we will ensure that any transfer of Personal Information is subject to applicable law and reasonable data protection security protocols.

We may also release your Personal Information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others rights, property, or safety.

Other than as required or allowed by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations), your Personal Information will not be used for any other purpose without your consent.

How do we protect your information?

We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational and technological measures to protect Personal Information, such as firewalls, encryption, and employee education.

We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information. In order for you to make use of the Site, we will retain your information until we receive a request from you to remove your information from the Site. If you do not log in to your account for a period of three years, we may also delete the information contained into your account.

Cross-border transfer of Personal Information

Your Personal Information may be processed or stored outside of the jurisdiction where you reside. Please note that the privacy laws in such jurisdictions may differ from privacy laws applicable in Canada. Reasonable contractual or other measures we may take to protect your Personal Information while processed or handled by these service providers are subject to applicable foreign legal requirements, including lawful requirements to disclose personal information to government authorities and law enforcement in certain circumstances. By submitting your Personal Information or engaging with the Site, you consent to such transfer and storage.

De-identified Information

We collect De-identified Information that is recorded by the standard operation of our Internet servers using Google Analytics, such as the operating system you are using, the sections of the Site you visit, and the Site pages read and images viewed. We do not knowingly track anyone under the age of 19.

We also collect De-identified Information when a student completes a “Student Ratings” features associated with our Subscription Accounts or Free Accounts. This consists of gathering of anonymized (‘star scale’) ratings from students about their teachers/lessons and anonymized regression analysis of teacher performance by matching student outcomes (for example, numerical scores on tests versus ratings).

This De-identified Information is used: (i) for Site and system administration purposes; (ii) to improve the Site and the Services’ product offerings; (iii) to conduct internal reviews of the number of visitors to the Site; (iv) to help us better understand visitors’ use of our Site and Services; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Site when necessary.

Cookies and Other Tracking Technologies

Cookies provide additional functionality to websites to better match users’ interests and preferences. With most Internet browsers, you can erase cookies from your computer hard drive, block the creation of cookies, or receive a warning before a cookie is stored, although doing so may affect your use of the Site and your ability to access certain features of the Site. Please refer to your browser instructions or the help section of your browser to learn more about these functions.

We use cookies to increase the quality of your experience while using the Service. For example, we use a cookie to remember which lesson plan you last opened on our Teacher Page. This way, when you come back to the library on our Teacher Page, the dropdown lists will be pre-loaded to the last lessons you opened.

Our Site may also use web beacons. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, web beacons will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

We may use De-identified Information, including but not limited to Student Ratings from Free Accounts (but not Subscription Accounts), to deliver Facebook Ads or Google Ads that are targeted to the interests of our Customers who have registered for our advertiser-supported Free Accounts (or whose Subscription Accounts have expired and reverted to Free Accounts).

OFF2CLASS WILL NEVER SERVE ADVERTISING TO YOUR STUDENTS, REGARDLESS OF WHETHER YOU SIGN UP FOR A SUBSCRIPTION ACCOUNT OR FREE ACCOUNT.

If you prefer not to receive targeted advertising, you can opt-out of some network advertising programs that use your information. For example, the Digital Advertising Alliance (DAA) Opt-Out Page at http://www.aboutads.info/choices/ provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies’ pages where you can opt-out of receiving targeted advertisements from those companies. In addition, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. Please note that even if you choose to opt-out of targeted advertising, you will still see advertisements while you are browsing online. However, the advertisements you see may be less relevant to you and your interests.

Third party links

Occasionally, at our discretion, we may include links to third-party products or services on our Site. These third-party websites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these third-party websites. You can contact our Data Protection Officer whose contact information is at the bottom of this policy for any comments about third-party links.

Children’s Online Privacy Protection Act Compliance

We make all reasonable efforts to be in compliance with the requirements of the U.S. Children’s Online Privacy Protection Act (COPPA), we do not collect any information from anyone under 13 years of age, without appropriate consent. This Site, our products, and services are all directed to people who are at least 13 years old or older. Third party (such as a student who you intend to use this Site with) information entered into this Site can only be entered by people who have the authority to enter that information. We will not be liable or responsible for any third party Personal Information that is entered on this Site without authorization. If a teacher enters information for a student who is under the age of 13, we recommend not entering any personally identifiable information. As noted above, you may enter a non-identifiable username and an anonymous (non-identifiable) email address and this will be sufficient for your student to use the Service.

Online Privacy Policy only

This online privacy policy applies only to information collected through this Site and not to information collected offline.

Changes to our Privacy Policy

We may modify, revise or update this Privacy Policy at any time by updating this posting. Each time you use the Site, the version of the Privacy Policy then posted will apply to that use, so you should check this page each time you use the Site.

Access to Personal Information including Subject Access Request (SAR)

If you have any questions about the accuracy of the Personal Information that we have collected about you, you can have access to that Personal Information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Information. You may also request to have your Personal Information removed from the Site.

You may contact our Data Protection Officer at the contact information below to request access to Personal Information that we have about you. We will respond to requests within 30 days and where requested, provide a copy of your Personal Information within 30 days.

Correcting Your Personal Information

We want to make sure that the Personal Information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information, unless it is necessary for us to do so to fulfil the purposes for which we collected the Personal Information.

Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed by updating your Account information or by contacting our Data Protection Officer as set out below.

Questions and further information

We are accountable for all Personal Information in our custody and control and have designated a Data Protection Officer, who is ultimately accountable for the handling of all Personal Information in our custody and/or control and for ensuring that the principles described in this Privacy Policy are being complied with. We make information about our privacy policies and practices readily available. If you have any concerns, complaints, or if you would like further information regarding our privacy policies or practices, please contact our Data Protection Officer at: privacy@off2class.com.