Avanti Privacy Policy

Last updated: April 9, 2021

At Avanti, privacy is a top priority and we are firmly committed to guarding the confidence you have placed in us and to use, responsibly and professionally, any information you provide. We will not ask you for personal information unless we feel it is necessary to provide our Service. This Privacy Policy applies to transactions and activities and data gathered through the service (“Service”) provided on our website (“Site”). The purpose of this Privacy Policy is to notify you of what information of yours is collected; how the information is used; with whom the information may be shared; what choices are available to you regarding collection, use and distribution of the Information; what kind of security procedures are in place to protect the loss, misuse or alteration of Information under our control; and how you can correct any inaccuracies in the information.

Please note that this Privacy Policy is a legally binding agreement made between you ("you," "your," or "yourself") and Avanti Tutoring Inc., a Delaware corporation, ("Avanti” "we," "us" or "our").

1. Your Information

In order to operate the Service, and to provide you with information about products or services that may be of interest to you, we may collect (a) "personal information" (i.e. information that could be used to contact you directly such as full name, phone number, home address and email address); (b) "demographic information" (i.e. information that you submit, or that we collect, including, but not limited to, zip code, hometown, gender, age/birth date, school information and registration history information); (c) “geo-locational data” (i.e. information that can be used to identify your physical location); and (d) “meta-data” (i.e. information which describes how, when and by whom a particular set of data was collected, and how the data is formatted. Collectively, this information is called “your information”.

2. Information Transfer

We only use your information as described in this Privacy Policy. We view protection of privacy as a critical community principle. We understand clearly that your information and your trust is one of our most important assets. We store and process your Information on computers that are protected by physical as well as technological security devices.

Please note that we may provide your information and information about your order to our subcontractors and to our marketing partners and affiliates for purposes of improving and marketing our Service. In addition, Avanti may share information about you or your order if we believe in good faith that disclosure of specific information is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Use; (b) comply with relevant laws or respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity (in which case we can, and you authorize us to, disclose personal information without subpoenas or warrants served on us); or (c) protect and defend our rights or property or the rights and property of you or third parties. We may also share aggregate information that does not identify you personally such as by publishing a report on trends in the usage of the Service. Further, as we continue to develop our business, we might sell or buy subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to applicable data protection laws and the promises made in any pre-existing privacy policy. Also, in the unlikely event that we, or substantially all of our assets are acquired, customer information will be one of the transferred assets.

3. Material You Choose to Reveal

If you post information, including personal information, on areas of the Service, it may be viewed by other users or the public, and we recommend that you do not do so. We urge you to use good judgment. Do not post any information, including without limitation, personal information, that you do not want other users to know. Many internet connections are public and/or not secure, and other users using that same connection may have access to your information; please make sure that you are using a secure internet connection.

YOU ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM YOUR VOLUNTARY DISCLOSURE OF PERSONAL INFORMATION.

4. Cookies/Personal Identifiers

In addition to the information gathered as described above, we may use cookies or similar data storage technologies (“personal identifiers’’) which are necessary to enable your use of the Service. If you have given your consent, we may further use these personal identifiers to track the content you view, and the nature of your interactions with other users of the Service each time you use the Service, so that we can better serve you when you return to the Service. We may also use such personal identifiers to help advertisers and publishers serve and manage ads provided on and through the Service.

Because personal identifiers allow you to take advantage of some of the essential features of the Service, we recommend that you allow access. For instance, if you block or otherwise reject personal identifiers, you may l not be able to use any services that require you to sign in.

5. Web Beacons

For our website, a “Web beacon,” also sometimes called a pixel tag or transparent GIF, is an object that is embedded in a web page. It is usually invisible to you, but allows website operators to check whether you have viewed a particular web page or email communication. We may place web beacons on our website, and in emails we send to you.

6. Third Parties’ Use of Web Beacons and Personal Identifiers

The Service may include third-party advertising, links to other websites, and other content from third-party businesses. These third-party sites, businesses, and advertisers, or advertising companies working on their behalf, may use Web beacons and personal identifiers to measure the effectiveness of their ads, personalize or optimize advertising content and to track users who link from their respective websites to the Service.

We do not have access to or control over such Web beacons or personal identifiers that these third parties may use. We are not responsible for the privacy practices or the content of these third-party websites. You are encouraged to review the privacy policies of the different websites you visit.

Some third-party advertising companies may provide a mechanism to opt-out of their technology. For more information about the opt-out process, you may visit the Network Advertising Initiative website, available at http://www.networkadvertising.org/managing/opt_out.asp.

7. Information Retention

To preserve the integrity of our databases, our standard procedures call for us to retain information submitted by users for an indefinite length of time. We understand your use of the Service as consent to store all your Information in one place for this indefinite length of time, if we so wish. If required by law, we will nullify user information by erasing it from our database. We will also respond to written user requests to nullify account information.

8. Choice/Opt-Out

We provide users the opportunity to opt-out of receiving communications from us and our partners at the point where we request personal information about you. We also give users the option to remove their information from our database, to not receive future communications or to no longer receive our service.

9. Our Security Precautions

Your payment information is encrypted and processed by a third party provider, Stripe, and cannot be seen by Avanti. Your profile is password-protected so that only you have access to your account information. In order to maintain this protection, do not give your password to anyone. Our staff will never proactively reach out to you and ask for any personal account information, including your password. You should never share devices. This will help protect your information entered on public terminals from disclosure to third parties.

Unfortunately, no data transmission can be guaranteed to be 100% secure. As a result, we cannot guarantee the security of any information you transmit, and you do so at your own risk. If you have any further questions on this issue, please refer to our Terms of Use. We expressly disclaim any liability that may arise should any other individuals obtain the information you submit.

10. COPPA

We do not knowingly collect personal information from children under the age of 13, in accordance with the Children's Online Privacy Protection Act ("COPPA"). If a parent or guardian becomes aware that his or her child has provided us with Personal Information (as defined in COPPA) without their consent, he or she should contact us at support@joinavanti.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files. We will also respond to written user requests to nullify account information.

11. California Consumer Privacy Act

This Section applies solely to visitors, users, and others who reside in the State of California. We adopt these provisions to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected

Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. NO Geolocation data. Physical location or movements. YES Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO Professional or employment-related information. Current or past job history or performance evaluations. YES Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. YES K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO Personal information does not include: • Publicly available information from government records. • De-identified or aggregated consumer information. • Information excluded from the CCPA's scope, like: o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994. We obtain the categories of personal information listed above from the following categories of sources: • Directly from our customers, potential customers or their agents. For example, from documents that our customers provide to us related to the services for which they engage us. • Indirectly from our customers, potential customers or their agents. For example, through information we collect from our customers in the course of providing services to them. • Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically. • From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information to apply for a position, we will use that information to process your application. • To provide you with information, products or services that you request from us. • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you. • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections. • To improve our website and present its contents to you. • For testing, research, analysis and product/service development. • As necessary or appropriate to protect the rights, property or safety of us, our clients or others. • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. • As described to you when collecting your personal information or as otherwise set forth in the CCPA. • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred. • When forwarding Digital Millennium Copyright Act (“DMCA”) infringement notifications, take down notices and counter notices. By submitting a DMCA infringement notification, counter notice or other communication, you consent to have this communication forwarded to the person or entity that stored or transmitted the content addressed by your communications. For notices other than DMCA infringement notifications and counter notices, you may request that we edit out your name and contact information. However, DMCA infringement notifications and counter notices (including any personal information set forth in the notifications) will be forwarded as submitted to us without any deletions • In connection with promotions that you may choose to participate in or referrals you give. Any information you submit in connection with promotions will be subject to the terms of the promotion, not this Privacy Policy. You will be given the option to consent to the use of your information at the time you sign up for the promotion/referral. You will not be required to participate in any promotion or referral, and if you do, you may choose to do so anonymously (including if you are below the age of 18 at the time of participating in the promotion/referral program).

We may host discussions or other moderated forums for users who can help each other with technical and general questions. Topics for discussion may include technical support questions and problems, suggestions for improvement, or anything else that relates to the Service. Please remember that any information that is disclosed in this area becomes public information and you should exercise caution when deciding to disclose your personal information.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we may have disclosed the following categories of personal information for a business purpose:

Category: Identifiers. Category: California Customer Records personal information categories. Category: Protected classification characteristics under California or federal law. Category: Professional or employment-related information.

We may disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates. • Service providers. • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you. • The categories of sources for the personal information we collected about you. • Our business or commercial purpose for collecting or selling that personal information. • The categories of third parties with whom we share that personal information. • The specific pieces of personal information we collected about you (also called a data portability request). • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o sales, identifying the personal information categories that each category of recipient purchased; and o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 3. Debug products to identify and repair errors that impair existing intended functionality. 4. Exercise free speech rights, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). 6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent. 7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 8. Comply with a legal obligation. 9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 3104134902. • Visiting our site: joinavanti.com/support.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services. • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. • Provide you a different level or quality of goods or services. • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

12. Changing our Privacy Policy for Previously Gathered Information

If at any point we decide to use particular personal information in a manner materially different from that stated at the time it was collected, we will notify users by way of an email and your continued use of the Service will constitute your acceptance of the new use terms. We also encourage you to review this Privacy Policy periodically. By using the Service, you do hereby represent and warrant that you have read, understand and agree to all terms of this Privacy Policy.

13. Contacting Us

If you have any questions about this Privacy Policy, our practices or your dealings with us, you may contact us at support@joinavanti.com.