Privacy Policy

Effective Date: January 1, 2024

Vivvi, Inc. (“Vivvi” or “we”) works with great companies to make exceptional care and learning more accessible and affordable. With trained, passionate teachers, flexible programs and global coverage across beautiful campuses, in-home, in-office and virtual tutoring offerings, we provide parents with peace of mind while offering employers an impactful way to honor and support their working families.This Privacy Policy describes how we use and share the personal information we collect in connection with the services we offer, including through our website, applications, and any other sites and facilities that refer to this Privacy Policy (collectively, the “Services”).

Before using the Services or submitting any personal information to the Company, please review this Privacy Policy carefully and contact us if you have any questions.

1. PERSONAL INFORMATION COLLECTION

Personal Information You Provide:

Identification and contact information, such as your name, email and mailing address, phone number, government identification, and contact and identification information for any children you enroll in the Services.
Transaction and payment information, including the Services you use, your payment details, and salary and billing information.
Communication information, including any information you provide when you contact us and when you respond to questionnaires, surveys or requests for market research.
Care and service records, including observations, assessments, and notes about your child’s activities and experience; information about you or your child’s schedules, relevant medical conditions, dietary requirements, and preferred activities; photographs and video feeds that we share with you in connection with the Services; and learning records and utilization reports.
Marketing preferences, such as your preferences for receiving communications about our activities and publications, and details about how you engage with our communications.
Any sensitive information you choose to provide as part of your care and services, such as information about your or your child’s allergies or dietary restrictions, medical conditions, and learning needs.

Information Collected Automatically. When you visit, use, and interact with the Services online, we and our service providers may create and automatically log information through the use of cookies and other local storage technologies. This information includes:

Device and connection information, such as the manufacturer and model of the device, operating system, IP address (including the location associated with your IP address or internet connection), unique identifiers, and browser you are using.
Usage information, such as information about how you use our Services online, including the types of content that you view or engage with, the features you use, the actions you take, the time, frequency, and duration of your activities, and your engagement with our emails and newsletters.

Information from Third Parties:

Employee benefits. If you receive our Services as part of an employee benefit, we receive information from your employer, such as your eligibility for the Services and other reporting information.
Other sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

2. PERSONAL INFORMATION USE

Your personal information is used for:

Service delivery, including to:

Comply with local regulations related to the delivery of services;
Provide, operate, maintain, secure and monitor the performance of the Services;
Create, maintain, and authenticate your account;
Process transactions;
Communicate with you about administrative matters such as scheduling and updates to our terms or policies; and
Provide support and respond to your requests, questions and feedback.

Service improvement and development, including to analyze the use of our Services for quality and training purposes and to develop new Services.

Marketing and advertising, including sending you direct marketing communications, such as newsletters and promotions, as permitted by law, and engaging advertising partners, including third party advertising companies and social media platforms, to show you relevant interest- based advertising online.

Compliance and protection, including to:

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims), including for health and safety purposes;
Audit our internal processes for compliance with legal and contractual requirements and internal policies; and
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

3. PERSONAL INFORMATION SHARING

We share personal information with the following categories of third parties:

Professional Advisors. We share personal information with professional advisors such as lawyers, accountants, bankers, auditors, and insurers where doing so is necessary to facilitate the services they render to us.
Compliance and Protection. We disclose personal information where required by law, to protect health and safety, and for the compliance and protection purposes described above.
Business Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your personal information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
Affiliates: We may share personal information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Vivvi. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy.

4. PERSONAL INFORMATION RETENTION

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.

5. CHILDREN

Our website is not intended for use by children under the age of 16 and Vivvi does not knowingly collect personal information from children under the age of 16 via our website.

6. SECURITY

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

7. YOUR CHOICES

Update or Correct Personal Information: To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct your personal information in our possession.

Opt Out of Marketing Communications: You may opt out marketing-related communications by following the opt-out or unsubscribe instructions contained in the marketing communication we send you. Please note, however, that if you do so you may continue to receive communications for Services delivery purposes.

Limit Online Tracking: There are a number of ways to limit online tracking, which we have summarized below:

Block Cookies: Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Use the following links to learn more about how to control cookies and online tracking through your browser:
- Firefox; Chrome; Microsoft Edge; Safari
Limit the Use of Advertising ID: Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Use Privacy Plug-Ins or Browsers: You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also install a browser add-on to opt out of Google Analytics.
Advertising Industry Opt-Outs: You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
- Digital Advertising Alliance
- Network Advertising Initiative
Platform Opt-Outs. The following advertising platforms offer opt-out features that let you opt out of use of your information for interest-based advertising:

Note that the above opt-out mechanisms are specific to the device or browser on which they are exercised. You will need to opt out on every browser and device that you use.

Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. Learn more about “Do Not Track” here.

8. CHANGES TO THE PRIVACY POLICY

The Services and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice (such as an email) is required by the applicable law.

9. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: hello@vivvi.co.

10. NOTICE TO EUROPEANS

Controller. For purposes of European data protection legislation, Vivvi is the controller of the personal data that is covered under this Privacy Policy. You can contact us using the information listed in the “Contact Us” section above.

European Representative. Our representative in the European Economic Area is:

VeraSafe Ireland Ltd.

Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland
+420 228 881 031

Justification for Data Processing. European data protection law sets out a list of justifications on which companies may rely to process personal data. We generally rely on one of the following justifications to process personal data:

Contractual Necessity, to provide you with the Services.
Legitimate Interests, where it is necessary for our legitimate business purposes, your interest or the interests of a third party.
Consent, where required by law. Where we rely on your consent to process personal data about you, you have the right to later withdraw your consent in the manner indicated when you consent or by contacting us as described in this Privacy Policy.

Our legal bases for processing the personal data are described in the table below.

Processing Purpose	Personal Data	Justification for Processing
Service delivery	Identification and contact information Transaction and payment information Care and service records Automatically collected data Sensitive information (if provided)	Legitimate interests in providing and administering our Sites and Services. If you contract with us directly for the delivery of our Services, that contract forms our legal basis for this processing. If you provide sensitive information, we use this information based on your consent.
Service Improvement and development	Care and service records Data from third parties Automatically collected data	Legitimate interests in analyzing, improving and developing our Sites and Services.
Marketing and advertising	Identification and contact information Communications Marketing preferences Data from third parties Automatically collected data	Legitimate interests in (i) sending you information regarding products and services that may be of interest to you and (ii) informing our marketing strategy. Consent for sending marketing communications regarding other products and services that may be of interest to you. Consent for using third-party marketing and advertising cookies.
Compliance and protection	Identification and contact information Transaction and payment information Care and service records Data from third party sources Automatically collected data	Legitimate interests in keeping our Services, network and information systems secure. Complying with law.

Your Rights. You have the following rights in relation to your personal information under certain circumstances and subject to any applicable exceptions:

Access. You may request information about, or to have access to, your personal information that we process.
Rectification: You may request to update personal information that is inaccurate or incomplete.
Erasure: You may ask us to delete or remove certain personal information that is no longer necessary for the Services where we have no other grounds to retain such information.
Restriction: You may ask us to restrict or ‘block’ the processing of your personal information in certain circumstances, such as where you contest the accuracy of the data or object to us processing it.
Portability: You may request access to some of your personal information in a structured, commonly used and machine-readable format.
Objection: You may object to our reliance on legitimate interests as the basis for processing your personal information that impact your rights.

Please see the “Contact Us” section above for information on how to exercise your rights. We may request specific information from you to help us confirm your identity and process your request. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Information Processing in the U.S. To provide our Services we will process your personal data in the United States for the purposes we have set out in this Privacy Policy. For more information on the safeguards we apply, please contact us at the address provided in the “Contact Us” section above.