POPULUS Privacy Policy

Populus Academy LLC and Populus Homestay LLC and their subsidiaries and affiliates (Collectively “POPULUS” or “We” or “us” or “our”) is committed to protecting the the privacy of the personal information you provide to us with respect to your access to and use of our websites and relevant POPULUS mobile applications (collectively “POPULUS Websites”).

This privacy policy (this “Private Policy”) is intended to inform you of our policies and practices regarding the collection, use, and disclosure of your personal information when you use POPULUS Websites.

BY VISITING OR USING POPULUS WEBSITES IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU EXPRESSLY CONSENT TO THE COLLECTION, USE AND PROCESSING OF YOUR PERSONAL INFORMATION BY POPULUS, ITS PARTNERS, CONTRACTORS AND PERMITTED AGENTS IN ACCORDANCE WITH THIS PRIVACY POLICY.

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Personal Information ("PI"): What PI do we collect?

The type of PI we collect depends on your relationship with us, as follows:

Unregistered User: If you are not a registered User, when you submit a query via our online “contact us” form, or otherwise email or call POPULUS, we may collect your name, email address, phone number, address and location.

Registered User: When you register a POPULUS account as a host, student, student parent, educator, or agent, we will collect your name, your chosen username and password, email address, mailing address, and profile picture (should you choose to provide one). If you register as a host, we will also ask you to provide information about your background to help us assess your suitability to be a host (including but not limited your education, occupation, household income, other family members’ names and ages (inclusive of children under 13 years old), detailed information about your house etc.), and banking details for payments. If you register as a student or student parent, we will also ask you to provide your bank or credit card details for payments, passport and nationality details, student registration details, and other information about you that will help us to find the right placement for you.

What other information do we collect?

Log Files: Any time you visit any POPULUS Website, our servers automatically gather information from your browser (such as your IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information. For example, we may log your IP address for system administration purposes. IP addresses are logged to track a user’s session. This gives us an idea of which parts of our site users are visiting. We do not share the log files externally.

Why must we collect your PI, and how do we use it?

How we collect your PI

We collect your PI as part of offering or providing our services and answering your questions. This includes PI you provide through POPULUS Websites (e.g. via our online contact us form, or when you register a POPULUS account with us) and during telephone calls. Generally, we collect your PI directly from you but may also collect your PI from other people or organizations if you have given consent for them to do so (e.g. an Education Agent for the student)

Why do we collect your PI?

We collect your PI for one or more of the following purposes (the “Main Purposes”):

(a) assessing your eligibility to enter into a business contractual relationship with POPULUS and/or your eligibility to fulfill your contractual obligations;

(c) fulfilling our contractual and legal obligations to you pursuant to the business contracts between you and POPULUS as well as applicable laws;

(d) administering your POPULUS account, including facilitating matters in relation to payments, insurance, and complaints;

(e) informing you of our updated products and services as well as the products and services of third parties that you might like to hear about;

(f) monitoring your use of POPULUS Websites and contacting you about changes to POPULUS Websites or for customer service purposes;

(g) creating and updating our database(s) for internal use;

(h) administering our relationship with you by responding to your enquiries; and/or

(i) any other purposes required or authorized by law.

If you refuse to provide us with your PI, we may not be able to carry out some or all of the Main Purposes.

How do we use your PI?

By providing your PI to us, you consent to us using your PI for the Main Purposes or any purpose that could be reasonably expected at the time your PI is collected. We may also disclose your PI to our agents, service providers, and other businesses partners for the purpose set forth herein.

We may also use your PI:

(a) for any purpose disclosed to you in an information collection statement at the point where we collect your PI; or

(b) for a purpose related or ancillary to one of the Main Purposes.

We may use certain non-personally identifiable information (such as anonymous usage data, IP addresses, browser type etc.) to improve the quality and design of POPULUS Websites, and to create new features, promotions, functionality and services by storing, tracking, analyzing and processing user preferences and trends as well as user activity and communications.

Can you remain anonymous or use a pseudonym?

We will, if practicable, allow you to use a pseudonym or to not identify yourself unless this is impractical or against the law.

In some instances, if you do not provide us with certain PI we may not be able to provide you with the relevant products, services, or information (including fulfilling the Main Purposes)). This may have an effect on whether we can begin or continue a relationship with you or allow you to use our services.

What disclosures will we make?

Disclosure to our Service Providers, Agents, and Business partners.

We may disclose your PI to our service providers, agents, and partners for the Main Purposes. We use a network of global third-party service providers in order to ensure that the services we provide to you are of the best possible standard. Some of our service providers, or the services they provide (like cloud-based storage solutions), are based outside of the USA. This could include places like Europe, Asia and Australia. In order to protect your information, we take care where possible to work with service providers who we consider maintain acceptable standards of data security compliance, and we do our part to meet those standards as they apply to POPULUS.

Disclosure to Other Users.

As an integral part of providing the Main Purposes, we may disclose your profile information to users. For instance, if you are a registered host, the photos and other profile information provided by you will be available to the student and/or student parents that are matched with you. Your PI may be communicated to your matches electronically or verbally by phone.

Disclosure by Law.

You acknowledge and agree that we may disclose your PI if required to do so by law, at the request of a third party, or if we, at our sole discretion, believe that disclosure is reasonable to (1) comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law); (2) protect or defend POPULUS , or a third party’s, rights or property; or (3) protect someone’s health or safety, such as when harm or violence against any person (including you) is threatened.

PI may be communicated electronically or verbally by phone. We may also disclose your PI in other ways with your consent or as required or permitted by law.

“Cookies” and related software

Our software may issue “cookies” (small text files) to your device when you access and use POPULUS Websites and you will be asked to consent to this at the time (e.g. when you first visit our website). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites.

POPULUS Websites use cookies and other tracking and monitoring software to: distinguish our users from one another; collect standard Internet log information; and to collect visitor behavior information. The information is used to track user interactions with POPULUS Websites and allows us to provide you with a good experience when you access any POPULUS Website, helps us to improve POPULUS Websites, and allows us to compile statistical reports on website visitors and website activity.

You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however please note that some of POPULUS Website features may not function if you remove cookies from your system. For further general information about cookies please visit www.aboutcookies.org or www.allaboutcookies.org.

How do we protect your PI?

We take all reasonable steps to keep your PI we hold secure and to ensure it is protected against misuse, loss, theft, unauthorized access, modification or inappropriate disclosure. We may hold PI in both hard copy and electronic forms in secure systems accessible only to authorized personnel.

POPULUS Websites use Secure Sockets Layer (SSL) encryption on all web pages where personal information is required and to make online purchases you must use an SSL-enabled browser in order to protect the confidentiality of your personal and credit card information while it’s transmitted over the Internet. You can help us by also taking precautions to protect your personal data when you are on the Internet. Change your passwords often using a combination of letters and numbers, and make sure you use a secure web browser.

Although POPULUS takes reasonable steps to safeguard and to prevent unauthorized access to your private information, it cannot be responsible for the acts of those who gain unauthorized access, and POPULUS makes no warranty, express, implied or otherwise, that we will prevent unauthorized access to your private information.

Opt-out

We offer you choices regarding the collection, use, and sharing of your personal information. When you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us, and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the promotional emails or text messages you receive or by contacting us.

If you register an account on POPULUS Websites, you may change any of your account information by editing it in your account page. You may request deletion of your account information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request, only after we have fulfilled such requirements). When we delete account information, it will be deleted from the active database, but may remain in our archives.

Privacy of Children

Protecting children’s privacy is especially important to us. We do not knowingly collect personal information from children under 13 for marketing purposes, but because some information is collected automatically, it can appear to be the personal information of the purchasers or users of the product and/or Services, and will be treated as such by this privacy policy. If a child under 13 submits personal information to POPULUS and we learn that that personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. It is our policy to comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws. Therefore, we restrict our Websites and Services to persons 18 years or older.

Links to other websites

Our Website may contain links to other websites. Unless the other website is one of POPULUS Websites, we are not responsible for the privacy practices of the owners of those websites. We recommend that you read the privacy policy of any website that asks you to provide your PI.

Data Retention

Because many users tend to use our services at different points of their student or accommodation needs, we retain your personal information for continued service and convenience purposes until you advise us not to do so (See section “Contacting us about privacy” below). Notwithstanding the foregoing, we may retain personal information in order to comply with applicable laws, keep accurate records, resolve disputes, prevent fraud, enforce our Terms of Use, the business contract between us, or other agreements, or for any other legally permissible purpose.

What will POPULUS do if there is a “Data Breach”

POPULUS is committed to managing personal information in accordance with privacy principles. We have systems and processes in place to ensure your data is secured and appropriately managed, including in the event of a suspected or known data breach. Any questions about data security can directed to us via the contact details below.

Privacy Policy Contact Information

You are responsible for ensuring that your PI is accurate, current and complete. If you have a registered account with us, you can update or change your PI and email preferences at any time via your POPULUS account’s profile page.

You may ask us to provide you with the PI we hold about you, subject to certain limitations under law. For your protection, we may require you to confirm your identity before access to your PI is granted. In most cases, we can provide you with a summary of your PI free of charge. However, in some circumstances, reasonable costs may be charged to you in accessing your PI, subject always to the law.

If you have a question or want to make a complaint about how we handle your PI, please contact us using the details below. We will review your complaint and will respond to you after we have carefully considered it. We may require further information from you in order to resolve any complaints. Requests may take up to 20 working days to complete.

We can be contacted via:

• Email: info@populusacademy.com

 

Contacting us about receiving a summary of your “PI”

If you wish for POPULUS to provide you with your currently held “PI” on your profile, across any of our services, please contact us as below:

• Email: info@populusacademy.com

 

Contacting us about removing your “PI” from the system

If you wish for POPULUS to remove your “PI” from our system, across any of our services, please contact us as below:

• Email: info@populusacademy.com

 

Please note that such removal may impact on your ability to access or use the Services that we provide.

Changes to this policy

We may amend, interpret, modify, or withdraw any portion of this Privacy Policy and related business practices at any time by posting updated text on POPULUS Websites, and your continued access or use of any POPULUS Website constitutes your consent to those changes.