Privacy Policy

Overview

Welcome to Enkulu!  The Enkulu websites and services are provided by Enkulu. (“Enkulu,” “we,” “us” or “our”).  We know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly.  This notice describes our privacy policy (“Privacy Policy”) for the Enkulu website (the “Site”) and mobile device application (the “App”).  The Site and App offer registered users the ability to practice their language skills on a live, video chat with a native language speaker. By using the Site and App, you consent to the current version of this Privacy Policy.  If you have questions or concerns regarding this Privacy Policy, you should contact the Enkulu Team by e-mail at hello@enkulu.vn.

Notice of Information We Collect And How We Use It

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience.  This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience better and easier. You may browse portions of our Site without providing us with personally identifiable information.  Certain use of the Site, and any use of the App, including the ability to practice language skills through a video chat session, require you to register through the Site or App, in which case we collect and store information, including personally identifiable information, that is voluntarily supplied to us by you when registering on the Site or App.   You can choose not to provide us with certain information, but by doing so, you may not be able to take advantage of our Site and App features and functionality.  We use personally identifiable information to deliver the Site and App to you and to develop analytics and aggregated data that allows us to improve our Site and App.  Once you give us your personal information, you are no longer anonymous to us. In addition to the specific usages outlined below, we may generally use any information we collect for the following purposes: For the purpose for which you provided the information to us, such as to create and maintain a user account for you; To provide the features and functionality of the Site and App to you; To personalize the content you see based on your personal characteristics and preferences; Improving our Site, App and other products and services; To troubleshoot problems, provide you with required notices, enforce our User Agreement (for example, when necessary to protect our or a third party’s intellectual property or proprietary rights), or to alert you to changes in our policies or agreements that may affect your use of the Site or App.

Information We Collect About Site Users

Log Files
Like many websites, we automatically gather certain information about our Site traffic and store it in log files.  This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.  We use this information, which does not by itself identify individual users, to analyze trends, to administer the Site, to track users’ movements around the Site and to gather demographic information about our user base.  We may link this automatically collected information to your personally identifiable information, in which case it will be used and disclosed as personally identifiable information under this Privacy Policy.
Cookies
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes.  We use both session ID and persistent cookies on the Site.  A session ID cookie expires when you close your browser.  We use session cookies to make it easier for you to navigate our Site.  A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.  We set a persistent cookie to store your password, so you do not have to enter it more than once.  Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our Site. We use marketing services provided by Google and other third parties that allow us to deliver advertising to users after they leave our Site that they will see elsewhere on the web.  This is a common practice called “remarketing.”  Users will not see more ads than they otherwise would see as a result of remarketing; rather, the ads they see are more likely to be ads for Enkulu products and services.  Google and any other third party marketing services providers we use to help us with remarketing use cookies as part of the remarketing service.  For more information regarding remarketing and the ability to opt-out, please visit: http://www.google.com/ads/preferences/, http://www.networkadvertising.org, http://www.aboutads.info If you reject cookies in your browser settings, you may still use our Site, but your ability to use some areas of our Site may be limited.
Clear Gifs (Web Beacons/Web Bugs)
We may employ a software technology called clear gifs, also referred to as web beacons or web bugs, that help manage content on the Site by tracking what content is effective.  Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Site users.  In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.

Information We Collect From Registered Users of the Site and App

Registration

During registration you are required to give truthful contact information in accordance with our User Agreement.  Registration requires you to provide us with: (i) a unique user name and password, (ii) your e-mail address, (iii) your country of domicile, (iv) your language preferences, and (v) your gender.  We use this information to create an account for you on the Site or App, contact you about the services on our Site and App in which you have expressed interest, and customize your experience based on your preferences.  For example, information on your country of domicile helps us provide you a Tutor in a comparable time zone.

Usage Information

In order to provide you with the best experience, we will collect data on your use of the Site and App, including but not limited to: (i) how long your video chat sessions last, (ii) what features of the Site and App you are using, (iii) when you access the Site and App and relevant features.  We may use all of the foregoing information as set forth in this Privacy Policy. We utilize Google Analytics, which uses log files and cookies (see above) to track certain information about visitors to the Site in the aggregate.  This service captures usage and volume statistics to allow us to analyze usage of our Site.  You can get more information about how Google Analytics collects information at http://www.google.com/analytics/ .

Device Information

When you use the App, we will collect non-personally identifiable information about the device you use to access the App, including but not limited to: (i) the device type, operating system and mobile carrier, (ii) language used by the device, and (iii) time zone used by the device.  For iOS-based devices, Apple also provides Enkulu with a device token and identification number that is specific to the device used to access the App.  This allows Enkulu to recognize your device when you log in to the App.

Payment

Students pay for minutes after a Session, in accordance with the fees listed in the Site or App at the time you initiate the Session, payment will occur through a third party payment systems (e.g., PayPal).  These third party vendors will require you to provide information used for billing and payment.  We do not have access to this payment information other than the amount of your purchase and information identifying you as the purchaser.  All uses of billing and payment information are governed by the respective policies of those third parties.

Recording of Sessions

We use a live video platform operated by a third party program. to provide you with ability to chat through live video with Tutors. If you engage in a video chat session on the Site or App, the session may be recorded as described in the User Agreement.  We may use such recordings for our internal business purposes, including without limitation for purposes of tutor evaluation, tutor training, dispute resolution and improving our service.  The recording may be made available to you and/or the other party to the recording for future viewing through the Site and/or App, or to you individually for review.  We may otherwise use the recordings as described in Section 9.4 of our User Agreement.

Tutor Notes

In order to provide you with a seamless exchange between multiple tutors, the tutors take notes on your conversation, based on information you provide during the video chat sessions.  This information includes, but is not limited to, your: age, gender, language preferences, tutor preferences (e.g. gender of the tutor), and interests.  We may retain any such information and associate it with your personally identifiable information.  This information will only be available to Enkulu personnel and the tutors with whom you interact.  We may use this information to match you with a particular tutor available on the Site and App and to provide you with information and services that are more likely to be of interest to you.

Correspondence

If you choose to leave us feedback, we will collect the information you send us.  We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. If you send us personal correspondence, such as e-mails or letters, or if other users or third parties send us correspondence about your activities or postings on the Site and App, we may collect such information into a file specific to you.

Communication from Us, the App or the Site

Special Offers and Updates

We may occasionally send you information on products, services, special deals, and promotions, using the e-mail address provided to us by you during registration.  To the extent we send you commercial e-mails regarding third party marketing or promotional materials, we will give you the ability to opt-out of receiving such e-mails in accordance with applicable law.  We will not provide your personally identifiable information to third parties for their own marketing purposes without your consent.

Push Notifications

You may receive notifications from Enkulu through the Apple’s push notification services.  By allowing push notifications to be sent when you download the App, you consent to all notifications sent to you through the App, which may include information on products, services, special deals and promotions.

Service-Related Announcements

We will send you strictly service-related announcements on rare occasions when it is necessary to do so.  For instance, if our service is temporarily suspended for maintenance, we might send you an e-mail. Generally, you may not opt-out of these communications, which are not promotional in nature.  If you do not wish to receive them, you have the option to deactivate your account.

Customer Service

We will communicate with you in response to your inquiries, to provide the services you request, and to manage your account.  We will communicate with you by e-mail, using the e-mail address provided by you to us when you registered on the Site or App.

Conditions Under Which Your Information is Shared

Aggregate Information (Non-Personally Identifiable)

We may share aggregated demographic information about our user base with our actual and potential advertisers and business partners.  This information does not identify individual users.  

Other Users

If you engage in any communication with another Site or App user, such user shall receive your user name, as well as any other personal information you may choose to share in connection with that communication.

Tutors

If you engage in a video chat session or any other communication with a tutor, such tutor shall receive your user name, as well as any other personal information you may choose to share in connection with such chat session.  Tutors may include any information you provide in their notes (see “Tutor Notes” above).

Share to Social Networking Sites

At the end of a video chat session, you will have the ability to “share” information about your recent session on a social networking site, like Facebook.  Provided that your tutor has consented, this may include a video of the session.  By “sharing” a session, you acknowledge that your posting is subject to the terms and conditions of the applicable social networking site.  We are not liable for any impermissible use of content on any social networking site or any other consequences of posting content on a social networking site.

Business Partners

We may disclose non-personally identifiable information to third party partners in furtherance of our business arrangements with them, including without limitation to jointly offer a product or service to you or create interoperability between our products and services and the products and services of such partners.

Service Providers

We may use contractors and third party service providers in connection with the Site and App.  When our contractors or service provider obtain access to your personally identifiable information, they are required to protect it in a manner that is consistent with this Privacy Policy by, for example, not using it for any purpose other than to carry out the services they are performing for Enkulu.

Other Disclosures

We reserve the right to disclose your personally identifiable information or any other information as required by law or when we believe that disclosure is necessary to protect our rights or the rights of a third party; to comply with a judicial proceeding, court order, or legal process; or in connection with an actual or proposed merger, acquisition or other corporate transaction or insolvency proceeding involving all or part of the business or asset to which the information pertains.

Links to Other Websites

The Site and App contains links to other websites that are not owned or controlled by Enkulu.  Please be aware that we are not responsible for the privacy policies of such other websites.  We encourage you to be aware when you leave the Site and App and to read the privacy policies of each and every website that collects personally identifiable information.  This Privacy Policy applies only to information collected by our Site and App.

Access to Personally Identifiable Information

If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, delete or deactivate it by making the change on our member information page, e-mailing our Customer Support at hello@enkulu.vn, or by contacting us by telephone or postal mail at the contact information listed below.

Security

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.  However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.  Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have any questions about security on our Site and App, you can e-mail us at hello@enkulu.vn.

Changes to our Privacy Policy

If we decide to change our Privacy Policy, we will post changes to this Privacy Policy and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.   We reserve the right to modify this Privacy Policy at any time, and such change will apply with respect to information you provide or your activity on the Site and App after the change in policy, so please review it frequently. If we make changes that materially affect our uses or disclosures of personally identifiable information that we have previously collected, we will contact you by e-mail, or by means of a notice on the Site and App to obtain your consent to have the changes to our Privacy Policy apply retroactively.

Contact Us

If you have any questions or suggestions regarding our Privacy Policy, please contact us at hello@enkulu.vn.