ROCKETHOUR (PTY) LTD PRIVACY POLICY

January 2025

1. INTRODUCTION

Welcome to RocketHour (Pty) Ltd ("RocketHour," "we," "us," or "our"). We are committed to protecting your personal information and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website (https://rockethour.com and all its sub-domains), and mobile applications (collectively, the "Platform") and the services we offer (the "Services").

By accessing or using our Platform and Services, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Platform.

Compliance with Laws

We comply with applicable privacy laws, including the Children's Online Privacy Protection Act (COPPA), the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR), the Protection of Personal Information Act (POPI), and other relevant laws. This Privacy Policy outlines your rights under these laws and how you can exercise them.

2. DEFINITIONS

In this Privacy Policy:

"Personal Information" (also referred to as "Personal Data"): Any information that relates to an identified or identifiable individual. This includes information that can identify you directly or indirectly, such as your name, email address, phone number, IP address, or other unique identifiers.

"Children": Individuals under the age of 13 or as defined by applicable local laws in your jurisdiction. For example, under the GDPR, this may refer to individuals under the age of 16 unless local laws set a lower age limit.

"Parents" or "Legal Guardians": Individuals who have legal authority to make decisions on behalf of a child, including providing consent for the collection and processing of the child's Personal Information.

"User" (also referred to as "you"): Any individual who accesses or uses our Platform and Services. This includes Students, Parents or Guardians, and Tutors.

"Student": A User who utilizes our Services for educational purposes, typically minors receiving tutoring.

"Tutor": A User who provides tutoring services through our Platform, including tutors, mentors, and educators.

"Platform": Collectively refers to our website (https://rockethour.com and all its sub-domains) and mobile applications through which we offer our Services.

"Services": The tutoring services, educational content, and related offerings provided by RocketHour through the Platform.

"Processing": Any operation or set of operations performed on Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction.

"Applicable Laws": All relevant laws, regulations, and legal requirements that apply to the collection, use, disclosure, and protection of Personal Information, including but not limited to COPPA, CCPA, GDPR, POPI, and other international data protection regulations.

"Consent": Any freely given, specific, informed, and unambiguous indication of the User's wishes by which they, through a statement or clear affirmative action, agree to the processing of Personal Information relating to them.

"Third Parties": Individuals or entities that are not the User, RocketHour, or RocketHour's employees or agents.

"Cookies": Small text files placed on your device when you visit our Platform, used to recognize your device, store preferences, and enhance your user experience.

3. INFORMATION WE COLLECT

We collect various types of Personal Information from users to provide and improve our Services. The types of information we collect depend on your interaction with our Platform and include:

3.1. Personal information collected from Users:

General personal details: Name, surname, date of birth, age, gender, nationality, and language preferences.

Contact information: Email address and phone number.

Account information: Username, password, profile picture, and preferences.

Usage data: Pages visited, time spent on the Platform, clickstream data, and aggregate statistical information.

Device information: Type of device used to access the Platform, operating system, browser type and settings, IP address, and dates and times of accessing the Platform.

Cookies and similar technologies: Information collected through cookies and other tracking technologies to enhance user experience and analyze usage patterns.

User communications: Personal Information included in correspondence with us, such as emails, chats, or customer support interactions.

Payment details: Payment method, billing address, transaction amounts, dates, and reasons for payments. We may also receive information from payment gateway service providers.

Views and opinions: Any opinions, comments, or feedback that you choose to share with us directly.

Legal and regulatory information: Information required for compliance with legal obligations, resolving disputes, and enforcing our agreements.

3.2. Additional information collected from Students:

Educational information: Academic performance, learning habits, goals, and other information relevant to tutoring services.

Session recordings and transcripts: Audio and video recordings of live tutoring sessions and automated transcriptions and summaries. These may include spoken words, visual identifiers, and any personal or sensitive information voluntarily disclosed during the session.

3.3. Additional information collected from Parents or Guardians:

Verification information: Proof of identity to verify parental consent, such as copies of identification documents or attestations.

Consent records: Records of any consent given for the collection and use of a child's Personal Information, including any withdrawals or refusals of consent.

3.4. Information collected from Tutors:

Professional information: Qualifications, certifications, background checks, and other information necessary to verify identity and assess suitability for providing tutoring services.

Payment information: Bank account details or payment preferences for compensation purposes.

4. HOW WE COLLECT INFORMATION

We collect Personal Information about you from the following sources:

Directly from you: When you sign up for our Platform and Services, fill out forms, communicate with us, or otherwise provide information directly.

Automatically through your use of our Platform: Via cookies and similar technologies, we collect information about your device, browsing actions, and usage patterns when you interact with our Platform.

From your use of our Services: Information generated during your interactions with our Services, such as transaction details and communications within the Platform.

From third parties and service providers: Information from affiliates, business partners, payment processors, and service providers who assist us in operating our Platform and providing our Services.

5. PURPOSES FOR PROCESSING PERSONAL INFORMATION

We process your Personal Information for the following purposes:

To provide and improve our services: To facilitate tutoring sessions (including the recording, transcription, and summarization of live video sessions), track your progress, personalize content to enhance your user experience, operate and manage your account or relationship with us, analyze usage patterns to ensure our Platform operates properly, develop new features, train and evaluate tutors, improve service quality, maintain a record of tutoring interactions for support, dispute resolution, and to protect the safety and wellbeing of students and tutors.

Communication: To contact you via email, SMS, push notifications, or other means to send newsletters and inform you about our services, updates, and promotions (with opt-out options).

Market research and analysis: To conduct market research and perform analysis to understand our business performance and user needs.

Fraud prevention and security: To prevent fraudulent activities and unauthorized access and to protect the security and integrity of our Platform and Services.

Administrative and operational purposes: To perform administrative tasks like managing and testing our processes, systems, security measures, and infrastructure for business operations.

Legal compliance: To comply with our regulatory, legal, and contractual obligations. This includes protecting our rights, privacy, safety, or property, and that of our users and others.

6. LEGAL BASES FOR PROCESSING PERSONAL INFORMATION

We process your Personal Information based on the following legal grounds:

Contractual necessity: Processing is necessary to perform our agreement with you or to take steps at your request prior to entering into an agreement.

Legitimate interests: Processing is necessary for our legitimate interests, such as improving our Services, conducting market research, ensuring security, recording and transcribing tutoring sessions to ensure service quality, training and evaluating tutors, resolving disputes, and protecting the safety and security of students and tutors, provided that your rights and freedoms do not override these interests.

Consent: We process certain Personal Information based on your consent, for example, for marketing communications. You have the right to withdraw your consent at any time.

Legal obligations: Processing is necessary for compliance with legal obligations to which we are subject.

In addition to the above purposes, we may use your Personal Information for other purposes if the law allows it, if you consent to it, or if it is in the public interest to do so. All processing of your Personal Information will be conducted in accordance with applicable laws.

We do not use automated decision-making processes, including profiling, that produce legal effects concerning you or similarly significantly affect you. If this changes, we will update this Privacy Policy and notify you as required by applicable laws.

7. PARENTAL CONSENT AND CONTROLS

We are committed to protecting the privacy of children and complying with the Children's Online Privacy Protection Act (COPPA) and other applicable laws. We do not knowingly collect Personal Information from children under the age of 13 without obtaining verifiable parental consent. Parents or legal guardians must provide consent before their child can access and use our Services.

7.1. Parental rights

As a parent or legal guardian, you have the following rights concerning your child's Personal Information:

Review information: You have the right to review the Personal Information we have collected about your child.

Request deletion: You can request the deletion of your child's Personal Information from our records.

Withdraw consent: You may withdraw your consent to the collection and use of your child's Personal Information at any time.

Refuse Further collection: You can refuse the further collection or use of your child's Personal Information.

To exercise any of these rights, please contact us at support@rockethour.com. We will take reasonable steps to verify your identity and your relationship with the child before fulfilling your request.

7.2. Age verification

We implement age screening measures to ensure that users are of appropriate age to use our Services. During the registration process, we ask users to provide their date of birth. If a user indicates that they are under the age of 13 (or the age of majority in their jurisdiction), we will require verifiable parental consent before allowing access to the Services.

7.3. Obtaining verifiable parental consent

We use reasonable efforts to obtain verifiable parental consent, which may include:

We use reasonable efforts to obtain verifiable parental consent, which may include requesting a signed consent form sent to us by mail, fax, or electronic scan; requiring the parent or guardian to use a credit card or other online payment system that provides notification of each transaction; or having the parent or guardian communicate with us via a video call or telephone call staffed by trained personnel.

We take special care to protect the privacy and safety of children. We do not condition a child's participation in an activity on the disclosure of more Personal Information than is reasonably necessary.

We maintain the confidentiality, security, and integrity of the Personal Information we collect from children. We retain children's Personal Information only as long as necessary to fulfill the purposes for which it was collected and as permitted by law.

7.4 Recording of tutoring sessions

As part of our Services, live tutoring sessions may be recorded and transcribed. Recording is optional and you can choose whether to enable this feature. When you opt in to recording, these recordings may capture your child's voice, likeness, and any information shared during the session. Students are notified at the start of each recorded session. Parents may not receive individual alerts for each recorded session, but can manage recording preferences in account settings at any time. These recordings are used to ensure the safety and protection of both students and tutors, support training and quality control, and enable us to respond appropriately to support inquiries or potential disputes. By opting in to session recording, you provide consent for these recordings and their internal use as outlined in this Privacy Policy.

8. DATA SUBJECT RIGHTS

8.1. Under CCPA (for California Residents):

Right to know: You have the right to request that we disclose the categories and specific pieces of Personal Information we have collected about you in the past 12 months.

Right to delete: You can request the deletion of the Personal Information we have collected and retained, subject to certain exceptions.

Right to opt-out: You can request that we do not sell your Personal Information to third parties. Please note that we do not sell Personal Information as defined under the CCPA.

Right to non-discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.

We do not sell Personal Information as defined under the CCPA. If this practice changes, we will update this Privacy Policy and provide a mechanism for you to opt-out. To exercise your rights, please contact us at support@rockethour.com

8.2. Under GDPR (for EU Residents):

Right to access: You have the right to request confirmation of whether we process your Personal Information and to access that information.

Right to rectification: You have the right to request that we correct any inaccurate or incomplete Personal Information we hold about you.

Right to erasure: You can request that we delete your Personal Information under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.

Right to restrict processing: You have the right to object to the processing of your Personal Information for certain purposes, including direct marketing and profiling.

Right to data portability: You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

Right to withdraw consent: If we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time.

8.3 Under POPI (for South African Residents)

Right to access: Request access to the Personal Information we hold about you.

Right to correction or deletion: Request correction or deletion of your Personal Information if it is inaccurate, irrelevant, or unlawfully obtained.

Right to object: Object to the processing of your Personal Information in certain circumstances.

Right to complain: Lodge a complaint with the Information Regulator if you believe your rights have been infringed.

9. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

We are committed to maintaining the confidentiality of your Personal Information and will only share it under the following circumstances:

Service providers and processors: We may disclose your Personal Information to trusted third-party service providers who assist us in operating our Platform and providing our Services, such as data storage providers, payment processors, and other vendors. These third parties only process your Personal Information on our instructions and in compliance with appropriate confidentiality and security measures required by applicable laws. This includes third-party platforms used for video conferencing and transcription (e.g., Google Meet, Gemini), which may temporarily process session recordings and transcripts on our behalf.

Affiliates and business partners: We may share your information with our affiliates or business partners to provide you with the Services and for internal business purposes. This includes companies under common ownership or control with RocketHour.

Legal and regulatory authorities: We may disclose your Personal Information to legal and regulatory authorities upon their request or when required to comply with legal obligations. This includes responding to court orders and legal processes or establishing, exercising, or defending our legal rights.

Professional advisors: Your information may be shared with our accountants, auditors, lawyers, and other professional advisors who are subject to confidentiality obligations. This is done in accordance with written agreements and for the purpose of obtaining professional services.

Business transfers: In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your Personal Information may be transferred or disclosed as part of that transaction. We will ensure that any recipient of your Personal Information agrees to protect it in a manner consistent with this Privacy Policy.

Defense of legal rights and safety: We may disclose your information to relevant parties when necessary to protect the rights, property, or safety of RocketHour, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

With your consent: We may share your Personal Information with third parties when you have given us explicit consent to do so.

When we engage third-party processors, we ensure that they process your Personal Information only based on our documented instructions, implement appropriate technical and organizational measures to protect your data and comply with confidentiality obligations and relevant data protection laws.

10. INTERNATIONAL DATA TRANSFERS

Due to the global nature of our Services and RocketHour's operations in multiple countries, your Personal Information may be transferred to and processed in countries other than your own—including the United States, where our servers are located for internal business purposes. We ensure that appropriate safeguards are in place to protect your Personal Information during such transfers, including:

Adequate data protection laws: Transferring your Personal Information to countries that have been deemed to provide an adequate level of data protection by relevant regulatory authorities.

Standard contractual clauses: Implementing written agreements, such as Standard Contractual Clauses approved by relevant authorities, which impose data protection requirements on the recipient equivalent to those under applicable data protection laws.

We will only transfer your Personal Information in compliance with applicable laws and ensure that it remains protected according to the standards outlined in this Privacy Policy.

Please be aware that if you transfer any Personal Information directly to a third party in another country (i.e., we do not facilitate or send your Personal Information to the third party), RocketHour is not responsible for that transfer of Personal Information, and such transfer is not governed by this Privacy Policy. Any Personal Information that we receive from a third party, regardless of origin, will be processed in accordance with this Privacy Policy.

11. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your experience on our Platform, understand how you use our Services, and improve our offerings. Cookies are small text files placed on your device when you visit a website. They help us recognize your device, store your preferences, and improve your user experience. We use the following types of cookies:

Necessary cookies: These are essential for the operation of our Platform. They enable basic functions like page navigation and access to secure areas.

Performance cookies: Collect information about how you use our Platform to help us improve it.

Functionality cookies: Remember your preferences to provide enhanced, personalized features.

Targeting and advertising cookies: Used to deliver relevant advertisements and track the effectiveness of our marketing campaigns.

Third-party cookies: Set by third parties to provide services like analytics or advertising.

Most web browsers allow you to control cookies through their settings. You can choose to refuse or delete cookies. However, doing so may affect the functionality of our Platform and your ability to access certain features. Our Platform does not currently respond to "Do Not Track" (DNT) signals. We adhere to the standards outlined in this Privacy Policy to manage the data we collect.

12. DATA SECURITY

We take the security of your Personal Information seriously and have implemented appropriate technical and organizational measures in accordance with applicable laws to protect it against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:

Encryption: Securing data transmission using industry-standard SSL/TLS protocols to protect your information during transit.

Access controls: Restricting access to Personal Information to authorized personnel who need it for their job responsibilities, and implementing authentication mechanisms to prevent unauthorized access.

Regular assessments: Conduct security audits and risk assessments periodically to evaluate and enhance the effectiveness of our security measures.

Please be aware that while we strive to protect your Personal Information, no method of transmission over the Internet or electronic storage is completely secure. Therefore, we cannot guarantee the absolute security of your data transmitted to our Platform. Any transmission of Personal Information is at your own risk.

We encourage you to help us safeguard your information by keeping your login credentials confidential and notifying us immediately at support@rockethour.com if you suspect any unauthorized use of your account or any other breach of security.

13. DATA RETENTION

We retain your Personal Information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by applicable laws. We take every reasonable step to ensure that your Personal Information is processed for the minimum period necessary.

Specific retention periods include:

Account information: Retained until your account is deleted or longer if required by law.

Transaction data: Retained for auditing, tax purposes, and legal compliance as required by law.

Communication logs and transcripts: Retained for customer service purposes and to establish, exercise, or defend our legal rights.

Session recordings: Retained for up to 6 months for internal review, training, and quality assurance purposes, unless needed longer for dispute resolution or legal obligations. Thereafter, the recordings are securely deleted.

We may also retain your Personal Information for legitimate business purposes. In some cases, we may keep your information in a de-identified or aggregated format indefinitely for statistical purposes, such as analyzing how users interact with our Platform and Services.

This Privacy Policy applies to the retention of your Personal Information. We may retain your data for the duration necessary to establish, exercise, or defend any legal rights, and we will ensure it is handled in accordance with this Policy during that time.

14. DATA BREACH NOTIFICATION

In the event of a data or security breach involving your Personal Information, we will notify the affected users and the applicable regulatory authorities within the time frames required by applicable laws. We are committed to complying with all legal obligations concerning such breaches. If you have any concerns about our privacy practices or suspect any breach regarding your Personal Information, please notify us immediately by sending an email to support@rockethour.com

15. USER CONTROLS AND OPT-OUT OPTIONS

You have control over your Personal Information and how it is collected, used, and shared. You can exercise your rights and manage your preferences in the following ways:

Marketing communications: Opt out of receiving marketing emails by clicking the "Unsubscribe" link in our emails or by adjusting your preferences in your account settings. Opt out of SMS messages by replying "STOP" or as instructed in the message.

Access and Correction: Access and update your Personal Information by logging into your account or by contacting us at support@rockethour.com.

Account Deletion: Request deletion of your account and Personal Information by contacting us at support@rockethour.com.

Cookie Preferences: Manage cookie preferences through your browser settings or our cookie management tool on the Platform.

16. LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our Platform may contain links to other apps, third-party websites, and services that are not under our control or supervision. These links are provided for your convenience and to help you find additional information on specific subjects. Please be aware that we are not responsible for the privacy practices, policies, or content of these third-party sites. Your use of and reliance on any information provided by such third parties is at your own risk.

We encourage you to review the privacy policies and terms of use of any third-party websites or services before providing them with your Personal Information. We cannot accept any responsibility or liability for the protection of your data by third parties.

17. POLICY ACCEPTANCE AND CHANGES

By accessing or using our Platform and Services, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms. We may update this Privacy Policy periodically. If we make significant changes, we will notify you via email or through the Platform. Your continued use of the Services after such modifications constitutes acknowledgment of the modified Privacy Policy.

18. CONTACT INFORMATION

If you have questions or comments about this Privacy Policy, please contact us:

Email: support@rockethour.com

19. LODGING A COMPLAINT

If you have any questions, concerns, or objections about our privacy practices or this Privacy Policy, please contact us at support@rockethour.com. We are committed to resolving any issues promptly and effectively.

You also have the right to lodge a complaint with the relevant data protection authority in your jurisdiction if you believe that we have not complied with applicable privacy laws.

For Users in the United States:

Federal Trade Commission (FTC)

Website: https://www.ftc.gov

Phone: 1-877-382-4357 (1-877-FTC-HELP)

For Users in the United Kingdom:

Information Commissioner's Office (ICO)

Website: https://ico.org.uk

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom

Phone: +44 303 123 1113

Email: casework@ico.org.uk

For Users in South Africa:

The Information Regulator (South Africa)

Website: https://www.justice.gov.za/inforeg/

Address: SALU Building, 316 Thabo Sehume Street, Pretoria, South Africa

Phone: +27 12 406 4818

Email: inforeg@justice.gov.za

For Users in the European Union (EU):

Under the General Data Protection Regulation (GDPR), you have the right to lodge a complaint with a supervisory authority in the Member State of your habitual residence, place of work, or place of the alleged infringement. Here's how you can find your local Data Protection Authority: European Data Protection Board (EDPB) Website: https://edpb.europa.eu/about-edpb/board/members_en

This link provides a list of national Data Protection Authorities (DPAs) for each EU Member State, including their contact details. If you believe your data protection rights have been violated, you can contact your local DPA to lodge a complaint.

20. CHILDREN'S DATA PROTECTION

We have a dedicated team focused on protecting the privacy of our younger users. We retain children's Personal Information only as long as necessary to fulfill the purposes for which it was collected and as outlined in Section 13 of this Privacy Policy. For any concerns related to children's data, please contact us at support@rockethour.com.

21. ACCESSIBILITY

We are committed to making our Privacy Policy accessible to all users. If you require this Privacy Policy in an alternative format, please contact us.

22. GOVERNING LAW

This Privacy Policy is governed by the laws of South Africa, without regard to its conflict of law principles.

23. EFFECTIVE DATE

This Privacy Policy is effective as of January 1, 2025.

© 2025 RocketHour (Pty) Ltd. All rights reserved.