Privacy Policy

Welcome to Cambly Inc.! We know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. Cambly, Inc. (“Cambly,” “we,” “us,” or “our”) provides this Privacy Policy (“Policy” or “Privacy Policy”) to describe the information we collect, how we use it, and when and with whom we share it. This Policy applies to the general-audience Cambly website (the “Site”) located at www.cambly.com, the Cambly mobile device application (the “App,” collectively with the Site, the “Services”). By accessing or using the Services, you agree to this Policy. If you do not agree to this Policy, please do not access or use the Services. Cambly Inc. is the data controller for your information.  

For information about our child-directed Cambly Kids website located at https://www.cambly.com/kids/student (“Cambly Kids Site”), please see our Children’s Privacy Policy located here for information on how we collect, use, and share personal information collected from children.

  1. The Information We Collect

We collect information about you through providing our Services. The types of information we collect depends on the Services and the features you use on the Services. Please note that we need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain Services.

    1. Information You Provide Directly to Us

We may collect information that you provide directly to us through:

The information you provide directly to us may concern you or others and may include, but is not limited to: 

You are not required to provide us with such information, but certain features of the Services may not be accessible or available, absent the provision of the requested information.

    1. Information from Affiliates and Non-Affiliated Third Parties

We may collect information about you or others through our affiliates or through non-affiliated third parties. For example, Cambly tutors may take notes on your conversations, based on information provided during tutoring sessions. We may combine information that we collect from you through the Services with information that we obtain from such third parties, such as if you sign in with a third party service or social media networks, and information derived from other products or services we provide.

    1. Information We Collect Automatically

Device/Usage Information. We and our third-party service providers, which include ad networks and analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Services. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use. We may also track when and how frequently you access or use the Services, including how you engage with or navigate our website or mobile application. We use this information (including the information collected by our third-party service providers) for analytics (including to determine which portions of the Services are used most frequently and what our users like/do not like), to assist in determining relevant advertising (both on and off the Services), to evaluate the success of our advertising campaigns, and as otherwise described in this Privacy Policy.

Cookies and Other Electronic Technologies. We and our third-party service providers may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Services. These technologies, for example, may allow us to tailor the Services to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about usage of our Services. We or our third-party service providers also may use certain of these technologies in emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

We may also use local shared objects (also known as "Flash cookies") to assist in delivering special content, such as video clips or animation. Flash cookies are stored on your device, but they are not managed through your web browser. To learn more about how to manage Flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser may not affect flash cookies. As we adopt additional technologies, we may also gather additional information through other methods.

Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address). 

  1. How We Use the Information We Collect

We use your information for business and commercial purposes, such as:

We may combine information that we collect from you through the Services with information that we obtain from affiliated and nonaffiliated third parties, and information derived from any other products or services we provide.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

  1. With Whom & Why We Share Your Information

We may share or disclose your personal information for the following reasons:

  1. Online Analytics and Advertising 
    1. Analytics

We may use third-party web analytics services on the Services, such as those of Google Analytics. These service providers use the sort of technology described in the “Information we collect automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

    1. Advertising

We may allow other third parties (e.g., ad networks and ad servers such as Google Analytics) to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technologies, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human-readable form.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's (“NAI”) Consumer Opt-Out Link and/or the Digital Advertising Alliance's (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI's and DAA's websites, accessible by the above links.

  1. Our Legal Bases for Use of Your Information

The laws of some jurisdictions such as the laws of the European Union require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your information. To the extent those laws apply, our legal grounds are as follows:

  1. Security of Your Information

We implement security measures to protect your information. It is important that you protect and maintain the security of your account credentials and you need to immediately notify us of any unauthorized use of your account. Please understand that no data transmission over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us.

  1. Consent to Transfer

Our computer systems are currently based in the United States, so your personal information will be processed by us in the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the Services, you agree to this Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer a level of protection equivalent to that required in the European Union, United Kingdom, or certain other countries, and to the processing of that information as described in this Privacy Policy.

  1. Children’s Privacy

The Cambly Kids Site contains content appropriate for children, including those under the age of 13 in the United States or 16 in all other jurisdictions (“children”), and may collect personal information directly from children. For more information about our distinct practices concerning collection, use, and disclosure of children’s personal information in connection with the Cambly Kids Site, please see our Children’s Privacy Policy

Our general-audience Services are not directed to children. If you become aware that your child has provided us with personal information through the Services, please contact us at help+legal@cambly.com. We do not knowingly collect personal information from children through the Services. If we become aware that a child has provided us with personal information, we will take steps to remove that information as required by applicable law and terminate the applicable account.

  1. Third-Party Websites

Our Services may link to third-party websites from companies other than Cambly, such as to relevant online resources, our partners’ websites, and other third-party websites. We are not responsible for the privacy practices or content of such other websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly. We are not responsible for the actions of third parties.

  1. Your Choices

You have certain rights and choices with respect to your information, such as:

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request.

  1. Changes to Our Privacy Policy

We may update this Policy from time to time. If we make material changes to our Policy, we will notify you and other users as required by law. By continuing to use our Services, you are agreeing to be bound by any changes or revisions made to this Privacy Policy.

  1. Contacting Us

If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email to help+legal@cambly.com or write to us at the following address:

Cambly, Inc.

340 S Lemon Ave. #4343

Walnut, CA 91789

  1. Supplemental Privacy Notice for California Residents

This Supplemental Privacy Notice supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents. It applies to personal information we collect on or through the Services and through other means (such as information collected offline and over the telephone). It does not apply to personal information we collect from our employees and job applicants in their capacity as employees and job applicants. It also does not apply to personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.

California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.

As described further in our Privacy Policy above, in the preceding twelve months, we or our service providers may have collected the below categories of personal information for business or commercial purposes:

We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; and (3) third parties such as social media networks and analytics or attribution partners.

We collect the categories of personal information identified above for the following business and commercial purposes:

Our Privacy Policy describes how we share personal information, such as when we share personal information with service providers or as required by law. In the previous twelve months, we may have shared certain categories of personal information with third parties (as that term is defined by the California Consumer Privacy Act) for business purposes. For example, if you are using the Services as a student, you may direct us to share your profile with Cambly tutors. Likewise, if you are using the Services as a tutor, you may direct us to share your profile with Cambly students and students can access video recordings of their tutoring sessions. The information in your profile may include the following categories of personal information: (1) identifiers; (2) demographic information; (3) information related to protected classifications; (4) audio/video data; and (5) other information that identifies or can reasonably identify you.  

Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.

If you would like to exercise any of these rights, please submit a request through this form or at help@cambly.com. You will be required to verify your identity before we fulfill your request. If you have an online account with us, logging into your account will serve to verify your identity and request, although we may request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

The CCPA sets forth certain obligations for businesses that “sell” personal information, including opting out of the “sale” of their personal information.  Although we do not believe we engage in the sale of personal information (and have not in the past twelve months) as we currently understand such term to be defined under applicable law and relevant regulatory guidance, we do share information as described in this Policy, including with certain analytics and advertising partners who perform certain services like analyzing our Services and showing you ads for Cambly. 

Depending on how you use the Services, we may share the following categories of information with analytics and advertising partners: identification and demographics; device information and identifiers, such as IP address and unique advertising identifiers and cookies; connection and usage information, such as browsing history or app usage; and inference data. If you would like to opt out of Cambly’s use of your information for such purposes, you may do so by opting out as set forth above in the section on Online Analytics & Advertising.

California Do-Not Track Disclosure

Cambly is committed to providing you with meaningful choices about the information collected on our Services for third party purposes. That is why we have provided links (above) to the NAI "Consumer Opt-Out" link, the DAA opt-out link, and a Google opt-out link. However, Cambly does not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.

California Shine the Light Disclosure:

California Civil Code Section 1798.83 permits customers of Cambly who are California residents to request certain information, once per year, regarding our disclosure of their personal information (as defined by California law) to third parties for their own direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such sharing. We do not currently share personal information with third parties for their own direct marketing purposes.