Cordial Experiences, Inc. (“CORDIAL” “we” or “us) is committed to protecting your privacy. This statement outlines our practices for gathering and disseminating information on the CORDIAL website and/or CORDIAL Services and explains the terms and conditions of your use of the Services. CORDIAL does not sell, rent, or trade the personal information of any of our customers to any third party. Please review our policy and contact us with any questions.

Collection of Personal Information

When you use or access the CORDIAL Services, you share certain personal information with CORDIAL. When you register with us, you may provide us with personally identifying information. Your decision to provide such information is voluntary. We collect this information in order to best respond to your use of our Services. If you choose not to share this information with us, it may not be possible for us to respond to your request.

Our registration form collects such items as name, email address, and telephone number, as well as information on the subjects for which you are requesting a tutor.

Should you choose to provide us with your telephone number or email address you may receive telephone, mail, or email contact from us with information regarding our products or services, special promotions, or upcoming events. You will be provided with the opportunity to opt-out of receiving such information in the future.

We may disclose personally identifying information in cases in which we have reason to believe that doing so is necessary to identify, contact, restrain, or bring legal action against someone who may be causing injury to or interference with CORDIAL, our property, customers, or anyone else who could be harmed by such activities, and in cases in which we believe in good faith that the law requires us to do so.

Your personal information is used by us for billing purposes, assessments of and provision of services to users; communication with you; and internal auditing.  We may also use the information that we collect to confirm that you are authorized to use the Services and to fulfill a requested transaction, including the processing of payments.

For service activities that request personal information, you agree to provide accurate and current information about yourself. Your registration and/or participation in our Services may be canceled without notice if at any time we discover that you provide false information, or violate any term of this Privacy Policy or our AUP.

CORDIAL will not disclose any of your personal information, except when we have your permission or under special circumstances, such as when we believe in good faith that disclosure is reasonably necessary to cooperate with local, state and/or federal law enforcement authorities, to enforce the AUP or prevent unauthorized use of the Services to respond to claims that any content in the Services violates the rights of third parties, protect the rights, property, or personal safety of CORDIAL, its users, or the public.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

CORDIAL relies on feedback from users regarding the Services provided. CORDIAL reserves the right to replicate your written comments about the service sent to our representatives via our website or the Services in promotional materials and/or in business development materials, along with your first name and company. Your email address and any personal information besides your name and company will not be used at any time without your agreement.  If you would like to make your comments anonymous, you may designate them as such in the Application.

We reserve the right to update our privacy and security policies and practices from time to time at our sole discretion. We will employ important safeguards against unauthorized disclosure or access to your personal information or other personally identifiable information about you, consistent with our Privacy Policy. HOWEVER, YOU ACKNOWLEDGE THAT SECURITY SAFEGUARDS, BY THEIR NATURE, ARE CAPABLE OF CIRCUMVENTION AND WE DO NOT AND CANNOT GUARANTEE THAT PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU WILL NOT BE ACCESSED BY UNAUTHORIZED PERSONS CAPABLE OF OVERCOMING SUCH SAFEGUARDS. IN PARTICULAR, OUR WEBSITE MAY BE USED TO ACCESS AND TRANSFER INFORMATION, INCLUDING PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU OVER THE INTERNET. YOU ACKNOWLEDGE AND AGREE THAT WE DO NOT OPERATE OR CONTROL THE INTERNET AND THAT UNAUTHORIZED USERS MAY USE VIRUSES, WORMS, TROJAN HORSES, AND OTHER DATA AND SOFTWARE TO OBTAIN ACCESS TO OR DAMAGE OUR WEBSITE OR PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU. Furthermore, we cannot be responsible for any personally identifiable information about you that you release on your own, or that you request or authorize us to release.

Links

The Services may contain links to other websites or materials posted online. CORDIAL is not responsible for the content or privacy practices of those websites. We encourage our customers or users to be aware when they leave our website, and to read the policies of any site that they may visit. The CORDIAL privacy statement applies solely to information collected by CORDIAL.

Security

We take every precaution to protect your information. When you submit information to us, your information is protected both online and offline. Online, we use firewalls, passwords and usernames to protect information. While we strive to protect your privacy and secure your information, we cannot guarantee the security of information sent via your personal Internet connection, and you disclose such information at your own risk.

The servers on which personally identifiable information is stored are kept in a restricted, secure environment, and are professionally maintained.

Privacy Shield Frameworks

Cordial complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  Cordial has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, CORDIAL is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also may correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their request to the contact information listed below.  If requested to remove data, we will respond within a reasonable timeframe.

We will also provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.  To request to limit the use and disclosure of your personal information, please submit a written request to the contact information listed below.

CORDIAL’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, CORDIAL remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless CORDIAL proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Cordial commits to resolve complaints about our collection or use of your personal information transferred to the United States pursuant to Privacy Shield.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Cordial at:

https://cordial.com/contact-us/

Cordial

RE: Privacy-Shield Inquiry

402 W. Broadway #700,

San Diego, CA, 92101

Cordial has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers  for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction