Privacy Policy

1. INTRODUCTION AND SCOPE

Welcome to Gypod (“Company”, “we”, “us”, or “our”). We operate the website gypod.com and related services (hereinafter referred to as the “Platform”). This Privacy Policy describes how we collect, use, disclose, and protect your information when you use our Platform.

We respect your privacy and are committed to protecting your personal data. This Policy is designed to comply with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable laws.

IMPORTANT NOTICE REGARDING AGE RESTRICTIONS:

The Platform and our services are intended solely for use by individuals who are at least eighteen (18) years old. By registering on the Platform, you represent and warrant that you are 18 years of age or older. We do not knowingly collect or solicit personal data from anyone under the age of 18. If we become aware that we have collected personal data from a person under the age of 18 without a valid legal basis, we will delete such data immediately.

2. DEFINING ROLES: CONTROLLER AND PROCESSOR

To ensure transparency in data processing, we clearly distinguish the areas of responsibility between the Platform and the Teachers.

2.1. Gypod as Data Controller

Gypod acts as a Data Controller with respect to:

• User account credentials (usernames, passwords, contact information) necessary for registration and access to the Platform.
• Technical data and metadata (access logs, IP addresses, device information).
• Teacher financial data necessary to process payments for Platform services.
• Marketing communications sent directly on behalf of Gypod.

2.2. Teacher as Independent Data Controller

In the context of conducting lessons and interacting with a Student, the Teacher acts as an Independent Data Controller. This means that the Teacher, not Gypod, bears sole legal responsibility for:

• Assessing the suitability of the Student and determining their educational needs.
• Verifying the Student’s age. If a Teacher decides to teach a minor (e.g., through a parent’s account), the Teacher is fully responsible for obtaining necessary consents from parents or guardians in accordance with the Student’s local laws.
• Lesson content, teaching materials, and any notes or records the Teacher maintains regarding the Student.

2.3. Gypod as Data Processor

With respect to video conferencing and content transmission during a lesson, Gypod acts solely as a technical intermediary (Data Processor) on behalf of the users. We provide the infrastructure for communication but do not control the content of the conversations.

3. INFORMATION WE COLLECT

We collect information that you provide to us directly, as well as information collected automatically when you use the Platform.

3.1. Data Provided by Users

(A) Teacher Data

Since paid features and professional tools are available to Teachers, the scope of data collected for this category of users is broader:

• Identity Data: Full name, profile photo, video introduction.
• Professional Data: Resume/CV, certificates, education details, work experience.
• Financial Data: Bank account or payment system details (for withdrawals or subscription/commission payments), Tax Identification Number (TIN) for compliance with tax laws (e.g., DAC7 in the EU or W-9 in the US).
• Verification Data: Copy of government-issued ID (Passport/ID card) for identity verification (KYC), if required to activate paid features.

(B) Student Data

• Basic Data: Name (or alias), email address.
• Age Confirmation: Declaration of being 18+ years of age.
• Payment Data: If a Student pays for services via the Platform, we collect payment instrument data (via a third-party processor); however, we do not store full credit card numbers.

3.2. Automatically Collected Information

• Logs and Devices: IP address, browser type, operating system, access times, pages viewed.
• Session Data (Telemetry): Metadata about video calls (duration, connection quality) necessary for billing and technical support. We do not record video or audio of lessons by default unless this feature is intentionally activated by users.

4. PURPOSES AND LEGAL BASES FOR PROCESSING

We process your data only when there is a lawful basis (in accordance with GDPR Art. 6).

5. DATA SHARING WITH THIRD PARTIES

We do not sell your personal data. We disclose it only in the following circumstances:

5.1. To Other Gypod Users

• Teacher Profile: Information from the Teacher’s profile (name, experience, video, price) is publicly available or available to registered Students to select a tutor.
• Student Profile: The Student’s name and information they choose to share in the chat are available to the selected Teacher.

5.2. To Service Providers (Processors)

We use trusted third parties to operate the Platform:

• Video Infrastructure: (e.g., LiveKit provider) for transmitting video streams.
• Payment Gateways: (e.g., Stripe, PayPal) for processing transactions.
• Cloud Hosting: (e.g., AWS, Google Cloud) for storing encrypted data.

5.3. Legal Requirements

We may disclose information if required by law, such as upon request by tax authorities (regarding Teacher earnings) or law enforcement agencies.

6. TEACHER LIABILITY AND DISCLAIMER

6.1. Teacher Autonomy

Teachers on the Platform are independent contractors, not employees of Gypod. Gypod does not control and is not responsible for teaching methods, schedules, or lesson content.

6.2. Student Age Verification

The Teacher acknowledges that Gypod does not conduct biometric or documentary verification of Students’ age. If a Teacher discovers that a Student is under 18 years old, the Teacher is obligated to:

1. Suspend the provision of services until age is confirmed or parental consent is obtained.
2. Independently ensure compliance with applicable child protection laws (e.g., COPPA, GDPR-K).
3. Gypod shall not be liable for the Teacher’s failure to comply with these obligations.

7. DATA RETENTION

We retain data for as long as your account is active or as necessary to fulfill legal obligations.

• Teacher Data: Financial and tax records are retained for the period prescribed by tax laws (typically 5–7 years), even after account deletion.
• Student Data: Upon account deletion, data is deleted or anonymized within 30 days, unless retention is required for dispute resolution.

8. YOUR RIGHTS

You have the right to access, correct, delete, and port your data.

• How to Exercise: Send a request to [email protected].
• Limitation: We cannot delete data that we are required to keep by law (e.g., Teacher transaction history). Additionally, we cannot delete data stored locally by a Teacher (e.g., lesson notes), as the Teacher is an Independent Controller of such data; in this case, you must contact the Teacher directly.

9. INTERNATIONAL DATA TRANSFERS

Gypod operates globally. Your data may be processed in countries other than your country of residence. We ensure data protection during cross-border transfers using Standard Contractual Clauses (SCCs) approved by the European Commission and other security mechanisms.

10. CONTACT US

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

• Email: [email protected]
• Address: Prilep str., 38, Blagoevgrad 2700, Bulgaria