Privacy Policy

1. What information does arabee collect about you?

arabee collects information in several ways from different parts of the Platform.

Information you provide to us. The type of personal information we collect may vary depending on your account type.

• School Information. When a teacher, school administrator, or other authorized person associated with a School registers for an account on our Platform or corresponds with us, we may collect personal information such as a name, e-mail address, payment information, username and password, and information about the School.
• Student Information. Once registered, a School will provide information about its students, such as student names or other identifiers, passwords, e-mail address for the student or the student’s parent or legal guardian, and educational level and topic of study. Personally, identifiable information collected from or about students, along with other information associated with that personally identifiable information is “Student Data.” The School may elect to provide user- names or identifiers which are not readily identifiable to anyone outside of the School community in lieu of a full student name, at its discretion. Additionally, some Schools may elect to use a Single Sign On (SSO) service like G Suite for Education rather than usernames and passwords to authenticate student access.
• Parent and Child Information. When a parent or guardian (“Parent”) registers for an account on our Platform or corresponds with us, we may collect personal information such as a name, e-mail address, payment information, username and password. We may also collect information about the child(ren) authorized by the Parent to use the Platform through the Parent’s account, including a profile name for the child user which may include a profile avatar. Each child user profile must be associated with a Parent account, and children cannot access the Platform without the Parent first signing into the Parent account with the Parent’s sign in credentials.
• Learning and Activity Information. During the course of providing the Platform, we collect information about your use of the Platform, as well as any information that you submit to the Platform, such as answers to questions. In addition, we may ask you for personal information at other times, such as when you contact our technical support team, send us an e-mail, complete a user survey or otherwise communicate with arabee.
• Information we receive from your use of our Platform. Like most websites and online services, arabee and our vendors automatically collect certain types of usage information when you visit www.arabeelearning.com, read our e-mails, use our Platform or otherwise engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, Locally Stored Objects (LSOs such as Flash or HTML5), log files, and similar technology (collectively, “tracking technologies”).

These tracking technologies collect information about how you access and use the Platform (e.g., referring / exit pages and URLs, how frequently you access the Platform, the pages you view, the links you click, and other actions you take on the Platform); information about your browser and information about the device(s) you use to access the Platform (e.g., Internet Protocol (IP address), browser type, browser language, Internet service provider, device type, model and manufacturer, a unique ID that allows us to uniquely identify your browser, device or account, operating system brand and model, and whether you access the Platform from multiple devices). We may also collect information about your geographical location data at the city level.

We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Platform and to understand more about the demographics and behaviours of our users. Although we do our best to honour the privacy preferences of our users, we are unable to respond to “Do Not Track” signals set by your browser at this time.

We use or may use the data collected through tracking technologies to secure the Platform, improve the Platform, to save you time, to provide better technical support, for promotional purposes, and to track website usage. For example, tracking technologies help us to:

1. 1- Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you.
2. 2- Remember your settings on the pages you visit, so that we can display your preferred content the next time you visit.
3. 3- Customize the function and appearance of the pages you visit based on information relating to your account; for example, to default you to a particular grade level, or to remember customized settings for a report.
4. 4- Track website usage for various purposes including website optimization, website improvement, sales, marketing, and billing.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and services (particularly those that require you to sign in) may not function properly if your cookies are disabled. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not prevent the collection of information through non-cookie technologies and does delete Local Storage Objects (LSOs) such as Flash objects and HTML5. We may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third-party tracking and online advertising” below.

2. How arabee uses the information we collect

We use the information we collect for the following purposes:

To provide and maintain the Platform. We use the information we collect to deliver the Platform to you. For example, we need to use your information to process payments, personalize learning curriculum, provide Schools, Parents and students with information and reports about student and child performance and use of the Platform, respond to inquiries and provide customer support.

To improve, personalize, and develop the Platform. We use information to tailor the content and information that we may send or display to users, to offer personalized content and instructions, and to otherwise personalize your experience while using the Platform, including on various devices you may use to access the Platform. We collect statistics to better understand how users’ access and use our Platform, monitor the effectiveness of our Platform, detect usage patterns, and to diagnose or fix technology problems. We also use information to demonstrate the effectiveness of the Platform and perform research, and to develop, support, and improve our Platform and other educational products and services.

To communicate with you. We use your information to provide transactional notifications for certain activities relating to your use of our Platform. For example, we may send e-mail notifications when a user completes an activity, to provide receipt for payment or other subscription notices. From time to time, we may send periodic promotional or informational e-mails to School or Parent users. We do not use Student Data to send marketing communications, and we do not send marketing communications to student or child users.

To promote safety and security and respond to legal process. We use information to promote the safety and security of our Platform, our uses and other third parties. For example, we may use the information to authenticate users, facilitate secure payments, detect and prevent fraud and other harmful activities, respond to legal requests or claims, and enforce our terms and policies. For personal data subject to the European Union General Data Processing Regulations (“GDPR”), we rely on several legal bases to process the data. These legal bases include where:

• - The processing is necessary to perform our contractual obligations in our Platform Terms or other contracts with you (as described in our Terms and conditions);
• - You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
• - The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
• - The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Platform, marketing the Platform, such as new features or products that may be of interest, and promoting safety and security as described above.

If you have any questions about or would like further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below in Section 14.

3. How does arabee share your information?

arabee may share or disclose your personal information as needed to provide our Platform or with your consent or permission. We may also share personal information in the circumstances described below.

Third parties with consent. We share information with consent and at the direction of Schools and Parents. For example, a School or Parent may direct arabee to share specific information with another individual, such as when a teacher directs arabee to send a communication to a parent. Similarly, we may share personal information with third parties, for example, if a School authorizes Google login or similar authentication tools for that School’s user accounts.

Others within the School. arabee may share information collected from users associated with a School with other users or persons designated by the School, such as teachers and school administrators of that School.

Vendors and Platform Providers.. arabee may share information with our trusted vendors, third party service providers and individuals to provide services or products for us or on our behalf, which may include analytics, hosting, billing, targeted advertising, and marketing. Some of these service providers or vendors may send you e-mails on arabee’s behalf. Vendors and service providers who have access to Student Data, if any, shall be contractually bound to uphold privacy and confidentiality terms no less protective than those provided herein.

Aggregate or De-Identified Information. We may share information in aggregated and/or anonymous form that cannot reasonably be used to identify an individual. For example, arabee may disclose aggregated user statistics (i.e., the total number or percentage of arabee users from a particular geographic region) in order to describe our services to current and prospective partners and other third parties, and for other lawful purposes.

Merger or Sale. If arabee becomes involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of its assets, your personal information may be transferred or disclosed in connection with the business transaction. In such an event, we will make efforts to provide notice before personal information is transferred and becomes subject to a different privacy policy. We will not transfer Student Data associated with School accounts in the event of a merger or sale unless the recipient has committed to The Student Privacy Pledge principles or similarly stringent privacy protections, or we will provide Schools with notice and an opportunity to opt-out of the transfer of Student Data by terminating their accounts and any associated student users before the transfer occurs.

Other. arabee may release personal information if it has a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to

(a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms and Conditions, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect the rights, property, or personal safety of arabee, its users, or the public; or (e) as required or permitted by law.

4. Third-party tracking and online advertising

arabee does not display any targeted advertising on the Platform at this time.

Please note that although we may permit third party advertising partners to collect information from visitors to the Platform for the purpose of displaying advertisements on other websites or online services on our behalf, we take many steps to prevent these third-party advertising networks from collecting information for targeted advertising purposes once a subscriber to our Platform signs into our Platform. Please note that we rely on cookies to identify whether you are a subscriber to our Platform and if you delete or block cookies, you may also delete the arabee cookie which prevents subscribers from receiving targeted arabee advertisements on other websites or online services.

We work with third-party online advertising networks which use technology to recognize your browser or device and to collect information about your visit to our Platform to provide customized content, advertising and commercial messages to you on other websites or services, or on other devices you may use. We (through the third-party advertising networks) use this information to direct our online advertisements to those people who may find them relevant to their interests. Typically, though not always, the information is collected through cookies or similar tracking technologies. You may be able to set your browser to reject cookies or other tracking technology by actively managing the settings on your browser or mobile device, though these tools may not be effective for all third-party tracking technologies, including Flash or HTML5 cookies. To learn more about cookies, clear gifs/web beacons and online advertising technologies and how you may opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s resources at www.aboutads.info/choices and/or the Network Advertising Initiative’s online resources, at www.networkadvertising.org.

5. How to control e-mail communications

arabee may, from time to time, send you e-mail regarding our products and services, or your use of our products and services. Only arabee (or its vendors or service providers operating on its behalf) will send you these e-mails. You can choose not to receive these e-mails by clicking the unsubscribe link in any e-mail or by contacting info@arabeelearning.com. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the Platform, or technical or security notices.

6. How to access, update or delete your personal information

You may edit your account information at any time by signing-in to your account, clicking on the account menu and selecting Profile & Settings. We recommend that you review your personal information periodically to ensure that it is accurate, complete, and current. If you do not provide and maintain accurate contact information for your account, we may not be able to provide you with the notices set forth in this Privacy Policy.

If you are a parent or guardian of a student who uses the arabee Platform through a School, please refer all questions and requests regarding access, modification, or deletion of your student’s user account or Student Data to your child’s school. The School may, at its discretion, address such requests with arabee and arabee shall respond promptly to all access, modification and deletion requests it receives from Schools.

Please contact info@arabeelearning.com for further instructions about deleting or deactivating your account or deleting your personal information. When account information is deleted, or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing and tax purposes or in old back-ups of their system.

7. How long does arabee retain your information?

We will retain personal information for as long as needed to provide the Platform and for our internal business purposes, which may extend beyond the termination or cancellation of your subscription or user account. For example, we may retain certain data as necessary to prevent fraud or future abuse, for recordkeeping or other legitimate business purposes, or if required by law. We may also retain and use information which has been de-identified or aggregated such that it can no longer reasonably identify a particular individual. All retained personal information will remain subject to the terms of this Privacy Policy.

Student Data. We will not knowingly retain Student Data beyond the time period required to support an educational purpose, unless authorized by a School or parent or required by law. We do not delete or de-identify any Student Data from an active student user account associated with a School except at the direction of the School or as a result of a breach of the Terms and Conditions of Service or this Privacy Policy. The School is responsible for maintaining current student rosters and identifying Student Data which the School no longer needs for an educational purpose by removing students from the school’s master roster or by submitting a deletion request.

Unless otherwise directed by a School or Parent, we will delete or de-identify personal information of student and child users after a period of inactivity, after the termination or cancellation of the license subscription, or after termination of our agreement with the School, in accordance with the terms of any applicable written agreement with the School, written requests from authorized School administrators or for any other reason in line with the Terms and Conditions of Service. Authorized School administrators may contact us at info@arabeelearning.com to request additional information about the retained information held on students

We may not be able to immediately or completely delete all data in all instances, such as information retained in technical support records, customer service records, backups, and other similar business records. We will not be required to delete any information which has been de-identified or disassociated with personal identifiers such that the remaining information cannot reasonably be used to identify a particular individual.

8. How does arabee protect your information?

Information Security. The security of your personal information is very important to us. We have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information we collect and to protect against unauthorized access to data. These include internal reviews of our data collection, storage, and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We restrict access to personal information to arabee employees, contractors, and agents who need to know that information in order to operate, develop, or improve our services. Our employees may be subject to disciplinary action, including termination, if they fail to meet privacy and confidentiality obligations. However, no security system is impenetrable—for that reason, we cannot guarantee the security of your personal information. If personal information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and take all steps required by applicable laws and regulations and our agreements with any affected Schools. All the data arabee sends and retrieves is encrypted between the browser and the Google Firebase cloud service – where it is stored in a secure and encrypted format. As such it will be subject to the privacy and security protocols in place on firebase. For more detailed information please see https://firebase.google.com/support/privacy/

Maintaining the security of your personal information also requires your cooperation and involvement. For your protection, remember to sign out of all accounts before closing your browser. There is a sign out link available on most arabee pages. After signing out, make sure to close all browser windows. In addition, do not use the “Remember” feature if you are signing into your account from a computer that other persons may have access to. This is to ensure that others cannot access your personal information if you share a computer with someone else or are using a public computer.

Please keep your password secure. If you have any concerns about the security of your account or the security of the Platform, we ask that you your concern to us immediately at info@arabeelearning.com We take all reported concerns seriously.

Data storage and transfer. arabee is located in the United Arab Emirates. Personal information collected through our Website and Platform is stored and processed on the cloud platform using Firebase. Firebase implements authentication and declarative rules for security.

9. European Union Data Protection

Residents in the European Union are entitled to certain rights with respect to personal information that we hold about them under the General Data Protection Regulation (GDPR) see link:

• Right of access and portability. The right to obtain access to your personal information, along with certain related information, and to receive that information in a commonly used format, and to have it transferred to another data controller;
• Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete;
• Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed;
• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information; and
• Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you need further assistance regarding your rights, please contact us using the contact information provided below (Section 14) and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

10. How does arabee protect children’s privacy?

arabee does not knowingly permit children under the age of 18 to create an account and does not knowingly collect personally identifying information from children under the age of 18 without the consent and at the direction of a Parent. Please contact us at info@arabeelearning.com if you believe we have inadvertently collected information from a child under 18 without parental consent so that we may delete the information as soon as possible.

Parents who purchase a subscription to the arabee Platform may set up a Child profile associated with the Parent’s account so that children under 18 may access the Platform under the Parent’s supervision. Please see our arabee Platform Children’s Privacy Policy to learn more about how arabee collects, uses and shares information associated with Child profiles. The Children’s Privacy Policy applies to all users of Child profiles, regardless of the age of the Child.

When arabee is used by a School in an educational setting, the School may authorize arabee to collect information from a child under 18. Please refer to Section 11 to learn more about how arabee protects Student Data, including Students who may be under the age of 18, when the Platform is used by a School.

11. How does arabee protect Student Data and comply with laws?

When arabee provides the Platform to Schools, our collection, use and disclosure of Student Data is governed by our Terms and Conditions of Use and/or any other agreement with the School, by the provisions of the Family Educational Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws that may relate to the collection and use of personal information of students. If you have any questions about our collection and use of Student Data, please contact us at info@arabeelearning.com. If you have any questions about reviewing, modifying, or deleting the personal information of a student, please contact your School directly.

The Student Privacy Pledge (“The Pledge”)). arabee adheres to the standards of the Student Privacy Pledge, an industry standard approach to privacy for educational service providers. The Pledge was created by the Future of Privacy Forum (FPF) and The Software & Information Industry Association (SIIA) and has been endorsed by the National School Boards Association (NSBA), the National Parent-Teacher Association (PTA), and the White House.

As part of our commitment to maintaining the standards of the Pledge, when we have access to Student Data through the provision of our Platform to a School, the following core principles guide our decisions around data, security, and technology:

• arabee does not collect, maintain, use or share Student Data beyond that needed for an authorized educational or school purpose, or as authorized by our agreement with a School.
• arabee does not use or disclose Student Data for targeted advertising purposes.
• arabee does not build a personal profile of a Student other than in furtherance of improving and developing arabee’s curriculum and offering for School purpose, or as authorized by a parent.
• arabee will maintain a comprehensive data security program designed to protect the types of Student Data maintained by arabee.
• arabee will not knowingly retain Student Data beyond the time period required to support the School’s purpose, unless authorized by the parent.
• arabee will clearly and transparently disclose our data policies and practices.
• arabee will never sell Student Data unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we will use our best efforts to ensure the successor entity honours the privacy commitments made in this policy and/or we will notify the School of such a sale and provide the School an opportunity to opt-out by terminating its account before the data transfer occurs.
• We will not make any material changes to our Privacy Policy or Terms and Conditions of Service that relate to the collection or use of Student Data without first giving notice to the School and providing a choice before the Student Data is used in a materially different manner than was disclosed when the information was collected.

The US Family Educational Rights and Privacy Act (“FERPA”). This Privacy Policy and our Platform are designed to meet our responsibilities to protect personal information from the students’ educational records under FERPA. We agree to work with each School to jointly ensure compliance with the FERPA regulations.

The Children’s Online Privacy Protection Act (“COPPA”). This Privacy Policy and our Platform are designed to comply with COPPA. We do not knowingly collect personal information from a child under 18 unless and until a School has authorized us to collect such information through the provision of the Platform on the School’s behalf. When a School uses our Platform in the classroom or in an educational context, we rely on the School to provide appropriate consent and authorization for a student under 18 to use the Platform and for arabee to collect personal information from such student, as permitted by COPPA. Upon request, we will provide the School the opportunity to review and delete the personal information collected from their students. If you are a parent and you have questions about your child’s use of our Platform and any information collected, you should discuss your questions with your child’s School.

Students Online Personal Information Protection Act (“SOPIPA”).

This Privacy Policy and our Platform are designed to comply with SOPIPA. We do not use Student Data for targeted advertising purposes. We do not use collected information to amass a profile of an arabee student except in furtherance of improving arabee school offering. We never sell Student Data unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we make efforts to ensure the successor entity honours the privacy commitments made in this policy and/or we will notify you of such a sale and provide you an opportunity to opt-out by deleting your account before the data transfer occurs. We will not sell students’ personal information to third parties other than in the context of a business transaction.

Student data, including covered information may be used for adaptive or customized student learning. Deidentified covered information may be used:

• To improve educational products
• To demonstrate the effectiveness of the products, including for marketing purposes
• To maintain, develop, support, improve or diagnose arabee’s product
• When aggregated, deidentified data may also be shared for development and improvement of our sites, services or applications.

Local Educational Authority “LEA”). This Privacy Policy and our Terms and Conditions of Use are designed to comply with a local educational agencies or authorities (LEA). In UAE these bodies are the Ministry of Education and Knowledge and Human Development Authority (KHDA) (henceforth referred to as “LEA’s”). Pupil records obtained by arabee from an LEA continue to be the property of and under the control of the LEA. Parents, legal guardians, or eligible pupils may review personally identifiable information in the pupil’s records and correct erroneous information by contacting their LEA directly. In the event of an unauthorized disclosure of a pupil’s records, arabee will notify the LEA and will provide the LEA with a report to be shared with the affected parent(s), legal guardians(s) or eligible pupil(s). Pupil records will be deleted and/or de-identified in accordance with our data retention and deletion policies described above in the section “How long does arabee retain your information.”

12. Links to other websites and services

The arabee Platform may contain links to and from third-party websites of our business partners, advertisers, and social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and their practices are not covered by this Privacy Policy. We strongly recommend that you read their privacy policies and Terms and Conditions of Use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

arabee does not endorse the information contained on those websites nor guarantee their quality, accuracy, reliability, completeness, currency, timeliness, non-infringement, merchantability or fitness for any purpose. The content in any linked website is not under arabee’s control, and if you choose to access any such web site, you do so entirely at your own risk.

13. Updates to this Policy

arabee may, in its sole discretion, modify or update this Policy from time to time, which will be reflected in the “Last Updated” webpage. If we change these Terms in a material manner, we may, but are under no obligation to, notify our users of the changes by posting a general notice on our Platform.

In any event, by continuing to use the Platform after those changes are made, you are expressing and acknowledging your acceptance of the changes. If you do not agree to any of the terms in these Terms or to any future terms in an update, do not use or access (or continue to access) the Platform.

We will not make any material changes to our Terms and Privacy Policy that would result in Student Data being used in a materially different manner than was disclosed when the information was collected without first giving notice to applicable Schools.

In the event that a School (as defined below) has entered into a signed, written agreement with arabee, changes to the Terms may not be effective as to the students of such school until either (a) the School affirmatively accepts the changes to the Terms, electronically or in a signed written agreement or (b) upon renewal of the School’s agreement with arabee at the end of the current term.

Each School shall maintain records of all use and copying, downloading or printing of the arabee Platform or content and assignment of all login identifications used to access the Platform. arabee shall have the right to examine such records and to audit your access to verify compliance with this agreement.

14. Contact Us

If you have a question regarding this Policy, or if a question was not addressed in these policies, you may contact us using the contact information below. We will do our best to answer your question promptly and accurately.

Ara Bee Education & Training Computer Software LLC, Office 148 Schon Business Park, Dubai Investment Park, Dubai, United Arab Emirates

Tel: (+971) 50 630 5414

General: info@arabeelearning.com

School: support.schools@arabeelearning.com

Family: support.family@arabeelearning.com

Website ww.arabeelearning.com