Privacy Policy

GoTu (“GoTu Technology, Inc.,” and as used here to include all affiliates under common ownership and control) is committed to protecting your privacy and protecting information that may be used to identify you: i.e., your Personal Information. This Privacy Policy sets forth the data collection and usage policies and practices that apply to Personal Information that GoTu may collect from or in regard to users of our website or apps (collectively, “our Sites”), or in regard to employees or agents of our clients or other business partners (collectively, “Users”).

By using our Sites or otherwise providing us with Personal Information, you acknowledge and agree to the terms of this Privacy Policy.

Information Security

GoTu maintains appropriate physical, electronic and administrative security standards and procedures to safeguard its data and systems. Moreover, all GoTu employees are required to comply with all privacy and security policies as a condition of employment. Employees are permitted to access and use only that personal and proprietary information necessary to perform their duties. We have made information security and data privacy foundational principles of our business operations.

Notice of Collection of Personal Information

We may collect the following categories of Personal Information about our Users:

Identifiers: We collect information when you create or update your GoTu account. This may include your name, email, phone number, login name and password, address, payment or banking information (including related payment verification information), government identification numbers such as Social Security number, driver’s license or government identification if required by law, professional licensure or certification, birth date, photo and signature. This also includes the preferences and settings that you enable for your GoTu account.
Online Activity: Internet and other electronic network activity information related to use of our Sites.
Cookies: GoTu’s website may deposit a small file called a “cookie” on a User’s computer hard drive to personalize their experience or track aggregate site visitation statistics.

Uses of Personal Information

GoTu uses the information gathered on our Sites for the purpose of operating and improving the Sites, fostering a positive User experience, and delivering GoTu’s services. In addition, Personal Information may be used for detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity, debugging to identify and repair errors that impair existing intended functionality, and undertaking internal research for technological development and demonstration.

No Information from Children

Our Services are designed for adults, not children. As such, we do not intend to collect Personal Information from persons under age 18, and specifically children under the age of 16, and our Services are not designed for such information. If you are under the age of 18, you are not permitted to use our Sites.

Disclosures for California Residents

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), provides California residents (“consumers”) with specific rights regarding their Personal Information. Similarly, the California Online Privacy Protection Act (“CalOPPA”) gives Consumers rights as to their online information. This California Consumer Privacy Statement (“CCPS”) sets forth our privacy practices as required by the CCPA and CalOPPA.

This section describes the CCPA rights of California residents and explains how to exercise those rights as follows. In the event of a conflict between the provisions of this CCPS and our standard Privacy Notice, the terms of this CCPS govern as to residents of California.

Notice Of Collection and Use Of Personal Information

If you use our Sites, we may collect the following categories of Personal Information about you:

Identifiers: We may collect identifiers such as your name, email, phone number, address, and other similar identifiers.
Sensitive Personal Information (Cal. Civ. Code § 1798.80): We collect certain “sensitive Personal Information” through our Sites, such as login name and password, insurance policy number, education, bank account number and other financial information, payment or banking information (including related payment verification information), government identification numbers such as Social Security number, driver’s license or passport if required by law, birth date, photo, signature, and geolocation.
Protected Classifications: We collect certain “protected classification” information, such as race or color, age, sex (including pregnancy), disability, national origin, and citizenship status.
Commercial Information: We may collect commercial information, including information related to any employer on whose behalf you are using our Sites.
Online Activity: We may collect website activity information, including, but not limited to, information regarding your interaction with our Sites.
Geolocation Data: We collect information about where the device from which you provide information is located.
Sensory Information: We do not collect audio, electronic, visual, and similar information through our website.
Biometric Information: We do not collect biometric information through our website.
Employment Information: If you are using our Sites on behalf of an employer, we may collect information about your employer and your job description.

We may use the categories of Personal Information listed above for the purposes described in this Privacy Notice. In addition, we may use these categories of Personal Information for certain business purposes specified in the CCPA, as described in this table, regardless of whether you are a California resident:

Purposes	Categories of Personal Information
Onboarding and providing services to our Dental Office client Users and our Dental Professional platform Users	Identifiers; Sensitive Personal Information; Protected Classifications; Commercial Information; Geolocation Data; Online Activity; and Employment Information
Auditing related to a current interaction with you and concurrent transactions	Identifiers; Sensitive Personal Information; Protected Classifications; Commercial Information; Geolocation Data; Online Activity; and Employment Information
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity	Identifiers; Sensitive Personal Information; Protected Classifications; Commercial Information; Geolocation Data; Online Activity; and Employment Information
Debugging to identify and repair errors that impair existing intended functionality	Identifiers; Sensitive Personal Information; Protected Classifications; Commercial Information; Geolocation Data; Online Activity; and Employment Information
Undertaking internal research and for obtaining input from you or a third party for technological or other website or service development and demonstration	Identifiers; Sensitive Personal Information; Protected Classifications; Commercial Information; Geolocation Data; Online Activity; and Employment Information

Hosting public forums such as blogs and chat rooms	Identifiers; Sensitive Personal Information; Protected Classifications; Commercial Information; Geolocation Data; Online Activity; and Employment Information
Hosting advertisements on behalf of GoTu and its business partners	Identifiers; Sensitive Personal Information; Protected Classifications; Commercial Information; Geolocation Data; Online Activity; and Employment Information
Hosting Contests and Awards	Identifiers; Sensitive Personal Information; Protected Classifications; Commercial Information; Geolocation Data; Online Activity; and Employment Information
Posting User Ratings	Identifiers; Commercial Information; Geolocation Data; Online Activity; Employment Information
Permitting Dental Offices and Dental Professionals to communicate via text and call	Identifiers; Commercial Information; Geolocation Data; Online Activity; Employment Information

Prior Collection, Use, or Disclosure of Personal Information

Any Personal Information collected, shared, sold or disclosed for a business purpose prior to the first Effective Date of this Privacy Policy was done so under terms substantially consistent with the terms of this Policy.

Sale of Personal Information

We may share your Personal Information with third parties for cross-context advertising, for which we may receive compensation. As such, we post a link – available here and on the home page of our website – for you to opt out of such sale or sharing, if you so desire.

Disclosure Of Personal Information for A Business Purpose

If you use our Sites, we may disclose all the categories of Personal Information about you described above to a third-party service provider if such vendor supports our provision of services to our Users.

Use of Automated Decision Making

We may use automated decision making to temporarily or permanently deactivate a User’s account if we detect patterns of activity that may be consistent with fraud or safety concerns.

Past 12 Months’ Activity

In the past 12 months, we have used Personal Information collected through our Sites or otherwise to facilitate our services to our Users, and to respond to User outreach. We have provided some such Personal Information to one or more third-party service providers for purposes such as cloud storage or other activities that support our provision of services to our Users. We have also provided certain Personal Information to third parties for cross-context marketing.

Retention Periods

We retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected.

Privacy Choices

If you are a California resident, you have certain choices regarding our use and disclosure of your Personal Information, as described below:

Access: The right to request, twice in a 12-month period, to have us disclose to you the Personal Information we have collected, used, disclosed and sold about you during the past 12 months.
Correction: The right to request that we make commercially reasonable efforts to correct information about you that is inaccurate.
Deletion: The right to request that we delete certain Personal Information we have collected from you. Your request to delete your Personal Information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA.
Opt-Out of Automated Decision-Making: The right to request access to and information about how automated decision technologies work and what their likely outcomes are, and to opt out of the use of automated decision-making technology, including profiling. However, we do not utilize automated decision-making technologies, so you have no need to affirmatively opt out.
Opt-Out of Sale: The right to opt-out of the sale of their Personal Information.
Opt-In if Under 16. The Personal Information of California residents who are 16 years old or younger may not be sold without that minor’s prior authorization. If the minor is less than 13 years old, their Personal Information may not be sold without “opt-in” authorization from a parent or guardian. As noted, however, persons under age 18 are not authorized to use our Sites.
Shine the Light Request: California residents have the right to request that we provide you with: (1) a list of certain categories of Personal Information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (2) the identity of those third parties. However, as noted above, we do not disclose Personal Information to third parties for direct marketing purposes.

How to Submit a Request or Opt-Out/In (California Residents)

For a California resident to submit a request, or to opt-out/into the sale or sharing of your Personal Information, email us at [email protected], or call us at 786-460-2170. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If you request access to or deletion of your Personal Information, we may require you to provide certain information to help us identify you. In addition, if you ask us to provide you with specific pieces of Personal Information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

The CCPA prohibits discrimination against a consumer because the consumer exercised any of the consumer’s rights under the CCPA. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. To request this Statement in an alternative format, email us at [email protected], or call us at 786-460-2170.

Only you, or a person that you authorize to act on your behalf, may make a request related to your Personal Information. In the case of access and deletion, your request must be verifiable before we can fulfill such request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. Under normal circumstances, we will provide you with requested information in a readily usable format, within forty-five (45) days of verifying your request. 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.

Changes

GoTu may amend this policy from time to time, and therefore encourages you to review it periodically. Your continued use of our Sites after any amendment is posted constitutes your consent to such amendment.

Contact Information

If you have any questions about this Policy, the practices of GoTu, or your dealings with our Sites, please contact GoTu as indicated below:

GoTu Technology, Inc.
100 SE 2nd Street, Suite 1300

Miami, Florida, 33131

U.S.A.

[email protected]

This privacy policy was last updated on June 18, 2024.