Terms and ConditionsPrivacy PolicyEducational Policy

Terms of Service

Last updated: August 7, 2023

This Terms of Service (the “TOS”) is entered into between you and (“you” or “your”) and Polis Educational Solutions, Inc. (“Polis”), and applies to Polis services, including but not limited to the Polis website at http://polis.ac (the “Website”), any domains or subdomains related to the Website and Polis personal education platform (altogether, the “Service”).

BY CLICKING “I AGREE” OR SIMILAR CONFIRMATION, BY CREATING AN ACCOUNT ON THESERVICE OR BY USING THE SERVICE YOU ARE AGREEING TO BE BOUND BY THE TOS.

  1.   DESCRIPTION OF THE SERVICE

Polis provides universities and colleges (each an “Institution”) as well as individuals with access to personalized 1:1 virtual advising to reduce student attrition, boost persistence, and achieve academic and career goals. Polis offers an online advising platform and marketplace to institutions and individuals that matches and connects students (each a “Learner”) with the world's best educators (each an “Educator”) for 1:1 virtual sessions related to academic advising, career guidance, and graduate school mentoring.  

  1.   ACCESS TO THE SERVICES

2.1 Age of Access.  You must be at least 18 or the age of majority in your jurisdiction (whichever is older) in order to use the Service and you represent and warrant that you have the right and authority to enter into and comply with this TOS.

2.2  Additional Restrictions.  You confirm that you have not been charged or convicted or plead guilty to a felony, including any and all sexually-related crimes.  If you are an Educator, you further confirm that you have not been subject to a suspension, citation, or reprimand that bars you from any university and/or school.  If you are a Learner, unless permitted in writing by both Polis and their applicable Educator, you shall not contact an Educator other than through the Service (such as through our internal messaging service, marketplace chat or Polis’s virtual meeting space), and if you do so, Polis may terminate your access to the Service.

2.3 Accounts and Login Information.  Access to the Service requires registering an account with Polis (each, an “Account”).  Polis may require you to verify your identity and select a username and password (“Login Information”) as part of registering an Account. You are responsible for managing and ensuring the security, confidentiality and authorized use of your Account’s Login Information and are prohibited from sharing your Login Information or your Account.  Polis strongly recommends that you keep your Login Information confidential, and you shall notify Polis promptly of unauthorized access or use of your Account.  If Polis, in its sole discretion, considers your Account to be unsecure or to have been used inappropriately, then Polis may immediately cancel the Account without any notice to you.

2.4 Verification.  Polis will do its best to verify the identity and credentials of all Learners and in particular Educators, although Polis is not required to take extraordinary measures to verify all Login Information or any additional verification or credential information provided to Polis by you.  Polis may, in its discretion, at any time, require additional verification information and may deny access to and use of your Account if Polis is not satisfied with the verification.  Polis may also require you to change or update your Login Information from time to time.  Polis may also add additional verification requirements for Educators or Learners at any time.  Polis also reserves the right to perform background checks of Learners and Educators, including criminal background checks, upon Account creation and at any time after the creation of an Account.

  1.   FEES

3.1 Fees (Individual).  As Learner, if you decide to use the Service by booking a session with an Educator (each a “Session”), you agree to pay the fees to the Educator, which shall be quoted to you at the time you request the Session (each a “Session Fee”).  Session Fees vary based on the particular Educator conducting the Session and may be modified by an Educator at any time.  Any modified Session Fee shall apply to any future Session(s) you reserve with your chosen Educator.  You are responsible for all Session Fees incurred by your Account, whether or not authorized by you.  All Session Fees must be made through Polis.  If a payment for a Session is made outside of Polis, Polis reserves the right to terminate any agreement with such Learner and/or Educator and may permanently ban such violators from the Service. Polis assumes no liability and no responsibility regarding any disputes or claims arising between a Leaner and an Educator if a Learner and Educator circumvent the terms of this TOS and meet outside the Service.

3.2 Fees (Institution).  If your Institution has provided you with subscription access to use the Service, the Institution is responsible for any Session Fees owed to the Educator for your Session. You may or may not be able to see the Session Fees for your Session depending on the specific arrangements or requirements of your Institution. If a payment for a Session is made outside of Polis, Polis reserves the right to terminate any agreement with such Learner and/or Educator and may permanently ban such violators from the Service. Polis assumes no liability and no responsibility regarding any disputes or claims arising between a Leaner and an Educator if a Learner and Educator circumvent the terms of this TOS and meet outside the Service.

3.3 Payment (Individual).  As a Learner, you shall provide Polis with credit or debit card (each a “Payment Card”) information and agree that Polis, or a third-party payment provider on behalf of Polis, may initiate payment for Session Fees automatically using such Payment Card upon your reservation of a Session.  Session Fees are processed by one or more third parties on behalf of Polis and such third parties may change without notice to you.  Polis does not store your Payment Card information internally and all Payment Card information is stored via third-party payment provider integration.

3.4 Payment (Institution). If you are an institutional Learner, your institution will handle all payments for services with Polis.  

3.5 Learner Cancellations and Rescheduling (Individual).  As a Learner, you can cancel or reschedule a Session up until 12 hours prior the start time of a Session without penalty.  Learners can cancel or reschedule a Session between 12 hours and 1 hour prior to the start of a Session, but will be charged 50% of the Session Fee.  If a Learner cancels or reschedules a Session less than 1 hour prior to the start time of the Session, shows up late to a Session, or does not show up to the Session, Learner shall be charged the full Session Fee.  Multiple cancellations or late arrivals will prompt Polis to review your Account and may result in a temporary or permanent suspension of your access to the Service.  Polis shall make exceptions for medical emergencies and other reasonable and relevant circumstances which prevent you from complying with the provisions of this TOS and the cancellation/rescheduling provisions.

3.6 Educator Lateness or Failure to Show. If an Educator shows up more than 5 minutes late to a booked session, the Learner may be entitled to a partial refund and/or one additional Session.  If an Educator does not show up for a scheduled Session, Learners should contact us immediately at polis@polis.ac; Learners will not be charged for a Session where an Educator does not show up. We will investigate the cause and provide the Learner with additional Educator recommendations and/or a discount on a future Session with the same or different Educator.

  1.   ADDITIONAL FEE CONCERNS (FOR EDUCATORS)

4.1 Payout Information. Educators are required to maintain updated and accurate banking or financial payout information as requested by Polis (“Payout Information”) in order to receive Session Fees from Learners.  If an Educator’s Payout Information is not up-to-date or accurate, Polis is not required to advise Educator to update such out-of-date or inaccurate information on behalf of Educator and any such issues may substantially delay an Educator’s receipt of a Session Fee.

4.2 Polis Commission. Polis receives a 34% commission fee for every Session Fee paid to an Educator and such commission is paid out prior to any Session Fee being paid out to an Educator.

4.3 Payments through Polis.  All Session Fees and any other payments made to Educators by Learners must be made through Polis.  If a payment for a Session is made outside of Polis, Polis reserves the right to terminate any agreement with such Learner and/or Educator and may permanently ban such violators from the Service.

4.4 Session Details.  For Educators, your individual hourly Session rate on Polis is determined by you as the Educator (“Hourly Rate”).  Please consider your rank, expertise, and experience, and average preparation time, among other factors, in setting your Hourly Rate. As an Educator, Sessions will be automatically booked by Polis based on the availability provided by you on your schedule.  Each Session Fee will be prorated accordingly depending on the length of a booked Session and your Hourly Rate.

4.5 Taxes.  Polis does not collect taxes on behalf of Educators as they are independent contractors who set their own Session Fees, but if required to do so in a particular jurisdiction by law, Polis may collect taxes (including but not limited to sales, use, gross receipts, value-added), duties and charges.

  1.   TERM AND USE OF THE SERVICE

5.1 Term.  Unless otherwise specified in writing by Polis, this TOS is effective starting on the date you create an Account (the “Effective Date”) and continues until terminated according to the TOS (the “Term”).

5.2 Authorized Use.  Polis is a community dedicated to learning and teaching, and Polis will not tolerate cheating, admissions fraud, or any forms of academic dishonesty.  During your use of the Service, you shall not violate the rules and policies of any academic institution, university, college, or school.  Furthermore, when using the Service, you may not:

a. knowingly provide false or inaccurate information to Polis;

b. decompile, disassemble or reverse engineer the Service;

c. alter, change or circumvent security related aspects of the Service;

d. export or share versions of the Polis marketplace to be posted or listed outside the Service;

e. misrepresent or misuse the affiliation or any trademark affiliated with an academic institution;

f. request a promise or guarantee of admission to any academic program or institution;

g. offer or suggest any payment or bribe (including for letters of recommendation);

h. use any automated system (bot, spider, etc.) to access the Service;

i. reproduce, rearrange, modify, change, alter, translate, create derivative works from, display, perform, publish, or distribute the Service;

j. break, disrupt or attempt to break or disrupt any device used to support the Service or other’s experience of the Service or knowingly exploit a flaw or bug in the Service;

k. store or transmit material that is infringing, libellous, unlawful or in violation of any person’s rights or a group of people’s rights;

l. use the Service to provide information or data to a competitor of Polis;

m. harass, abuse, stalk, threaten or impersonate any person or group of people, including any Polis contractor, employee or agent (including an Educator);

n. use hate speech, hate terms, racist speech, racist terms or any other words or symbols that signify hate towards any person or group of people, including derogatory comments against women or minorities;

o. sell, rent, lease or sublicense the Service or access thereto, unless expressly permitted by Polis;

p. promote, encourage or undertake illegal activity; or

q. infringe or violate third-party rights including but not limited to: (i) contractual rights; (ii) copyright, patent, trademark (including university/academic trademarks) or trade secret rights; (iii) privacy rights; (iv) publicity rights; or (v) confidential information,

as determined by Polis in its sole and absolute discretion.

5.3 Suspension and Termination.  Polis may suspend or terminate access to the Service, without notice or compensation to you, at any time for any reason (or for no reason) including but not limited to technical issues, a lack of professional courtesy in your interactions with Polis (including with any contractors, employees, Educators or other Polis support staff), your non-compliance with the TOS, failure to pay a Session Fee, or your failure to adhere to the terms of an agreement with Polis.  Polis has sole discretion to lift a suspension or reverse terminated access.  Your access to the Service automatically terminates upon the earliest of the date: (a) You or Polis terminates your access to your Account; (b) of your non-compliance with the TOS, as determined by Polis in its sole discretion; or (c) 30 days following the date on which you provide notice to Polis of your intention to terminate the Service.  

5.4 Privacy Policy and Privacy Law Compliance.   Your use of the Service is governed by a Privacy Policy detailing how Polis collects, uses, and discloses personal data about you, and is available at http://polis.ac/privacy.  By agreeing to the TOS and/or using the Service, you represent and warrant that your use of the Service complies with applicable privacy laws and are permitted to share the personal data that you share with Polis. If at any time you disagree with the Privacy Policy, you must immediately stop use of the Service and contact Polis at polis@polis.ac.

  1.   PROPRIETARY RIGHTS

6.1 Polis Ownership and Rights.  Polis retains all right, title and interest in the Service, including but not limited to copyrights, copyrightable works, patents, patent rights, trademarks, trade names and trade secrets.  The TOS does not convey any right, title or interest in, or constitute the sale of any right to the Service or any related software used as part of the performance of the Service.

6.2 User Ownership and Rights.  You retain all right, title and interest in all information, content and data owned or licensed by you that you upload or share through the Service, allow Polis to access during your use of the Service or communicate directly with your Educator or Learner (“User Property”).  The TOS does not convey any right, title or interest in, or constitute the sale of any right to, User Property, and you represent and warrant that all consents, licenses and rights necessary to license User Property are obtained prior to the sharing any of User Property with Polis.  Polis shall not use or access User Property stored with us except when you request that Polis use User Property in order to facilitate your use of the Service and only as reasonably limited by your request, and in such cases you hereby grant Polis a limited and revocable license to User Property under all copyright, trademark, trade secret, patent, privacy and publicity rights and any other intellectual or industrial property rights you own or control to use, display, modify, record, translate, transmit or otherwise exploit in order to facilitate the provision of the Service to you and no more.

6.3 Publicity.  You and Polis are both prohibited from publicly disclosing (including on social media), issuing any press releases or making any other public statement, or communicating with the media, concerning any Confidential Information (defined below), including any details that contain personal information from any Session between a Learner and an Educator, without the prior written approval of the relevant Learner, the relevant Educator (if applicable), and Polis, which may be withheld for any reason or no reason.  

6.4 Feedback.  Notwithstanding the foregoing publicity restrictions, unless otherwise agreed to in writing, Polis may use your name and other communications in Polis marketing and promotional materials in the limited context of reviews, rating and comments about Educators that you interacted with through the Service (“Feedback”).  By submitting Feedback, you agree that: (a) your disclosure is voluntary, free, unsolicited, and without restriction; (b) your Feedback does not contain the confidential or proprietary information of third parties; and (c) we are free to use the Feedback without any compensation to you and to disclose the Feedback on a non-confidential basis or otherwise to anyone.

  1.   NON-DISCLOSURE, NON-SOLICITATION AND SECURITY

7.1 Confidential Information.  Polis, including through an Educator or a Learner, and you may receive (each, a “Recipient”) confidential information not known or available outside of the other party (the “Discloser”) (except when known outside the Discloser and under a duty of confidentiality) including but not limited to: personal information (as defined in applicable privacy laws), educational information, educational materials, business plans, product or service plans, analyses, forecasts, predictions or projections, intellectual property, trade secrets, software, code, hardware, prototypes, technology, technical information, business models, pricing and pricing strategies, marketing ideas, data (including sales data), sales projections, customer lists, employee lists, financing plans, valuations, capitalization, budgets and other non-public information (collectively, “Confidential Information”).  Notwithstanding the above, Confidential Information excludes: (a) any information generally available to the public (otherwise than through any act or omission of Recipient); (b) any information obligated to be disclosed by law; and (c) any information known by Recipient prior to the Effective Date or obtained from a third party who is not under a confidentiality obligation to you and who has not received such Confidential Information from another in breach of a duty of confidentiality to Recipient.

7.2 Non-Disclosure.  Recipient shall not disclose or use Confidential Information for any purpose other than to provide information, or to undertake work, requested by directly by Discloser that requires use of Confidential Information.  Recipient shall not disclose any Confidential Information of Discloser except to its employees, contractors or agents on a need-to-know basis and only if such employees, contractors or agents agreed to similar confidentiality terms.  If Recipient becomes aware of any unauthorized disclosure or use of Confidential Information, Recipient shall promptly notify Discloser of such disclosure or use.  Recipient acknowledges and agrees that no rights or licenses to Confidential Information are granted or implied by this TOS except as explicitly stated in this TOS.

7.3 Non-Solicitation.  During the Term and for a period of 12 months immediately following the end of the Term, you shall not, directly or indirectly, on its own or on behalf of a third party, hire, retain or solicit any client, any Educator, employee or independent contractor of Polis about whom you became aware of, or with whom you had contact, over the course the Term.

7.4 Security.  Polis is committed to ensuring that anything you share with us is secure.  In order to prevent unauthorized access or disclosure of User Property or the Service, Polis has put in place suitable physical, electronic and managerial procedures to safeguard and secure Polis systems.

  1.   DISCLAIMER AND LIMITATION OF LIABILITY

8.1 DISCLAIMER.  THE SERVICE IS PROVIDED TO YOU “AS IS” AND POLIS AND ITS SUBSIDIARIES, AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, REPRESENTATIVES AND ASSIGNS (COLLECTIVELY, “REPRESENTATIVES”), DISCLAIM ALL REPRESENTATIONS, WARRANTIES AND CONDITIONS, EXPRESS, IMPLIED OR STATUTORY, INCLUDING WITHOUT LIMITATION MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT OF THIRD-PARTY RIGHTS OR COMPLIANCE WITH LAWS WITHIN YOUR JURISDICTION.  WITHOUT LIMITING THE FOREGOING, POLIS MAKES NO REPRESENTATIONS THAT USE OF THE SERVICE WILL NOT INFRINGE ANY COPYRIGHT, PATENT, TRADEMARK LAW OR OTHER RIGHTS HELD BY A THIRD PARTY.  FURTHER AND WITHOUT LIMITING THE FOREGOING, POLIS AND ITS REPRESENTATIVES MAKE NO REPRESENTATIONS OR WARRANTIES THAT THE SERVICE, SERVICES PERFORMED AND PRODUCTS PROVIDED BY POLIS OR OTHER THIRD PARTIES, WILL COMPLY WITH APPLICABLE LAWS WITHIN YOUR JURISDICTION, MEET YOUR REQUIREMENTS, NOT CAUSE DAMAGE TO YOU, USER PROPERTY OR PROPERTY OF OTHERS, OR THAT OPERATION OF THE SERVICE WILL BE UNINTERRUPTED, CONTINUOUSLY AVAILABLE, ERROR FREE OR WILL NOT HARM YOUR COMPUTER OR MOBILE DEVICE OR RESULT IN LOST DATA.  NO ORAL ADVICE OR WRITTEN INFORMATION PROVIDED BY POLIS AND THE REPRESENTATIVES WILL CREATE ANY WARRANTY AND YOU SHALL NOT RELY EXCLUSIVELY UPON SUCH ADVICE OR INFORMATION.  YOU BEAR THE ENTIRE RISK AS TO THE PERFORMANCE, OPERATION AND QUALITY OF THE SERVICE.

8.2 LIMITATION OF LIABILITY.  POLIS AND ITS REPRESENTATIVES SHALL NOT BE LIABLE TO YOU FOR ANY CLAIM, LOSS OR DAMAGE OF ANY KIND ARISING OUT OF OR RELATING TO THE SERVICE OR THIRD-PARTY SERVICES, INCLUDING WITHOUT LIMITATION DIRECT, CONSEQUENTIAL, INCIDENTAL OR SPECIAL DAMAGES.  TO THE EXTENT THAT THE ABOVE LIMITATION OF LIABILITY IS NOT APPLICABLE IN YOUR JURISDICTION, ANY CLAIM THAT YOU MAY HAVE AGAINST POLIS AND THE REPRESENTATIVES MUST BE COMMENCED NO LATER THAN 6 MONTHS AFTER THE DAY ON WHICH THE CLAIM IS DISCOVERED OR OUGHT TO HAVE BEEN DISCOVERED BY YOU.

8.3 MAXIMUM AGGREGATE LIABILITY.  NOTE THAT SOME JURISDICTIONS DO NOT ALLOW THE DISCLAIMER OF CERTAIN TERMS OR WARRANTIES OR EXCLUSION OF LIABILITY FOR CERTAIN DAMAGES AND, IF ANY DISCLAIMER OR LIMITATION OF LIABILITY IS FOUND UNENFORCEABLE, VOID OR DOES NOT FULLY SHIELD POLIS AND THE REPRESENTATIVES FROM LIABILITY, YOU AGREE THAT POLIS’S (AND THE REPRESENTATIVES’) MAXIMUM AGGREGATE LIABILITY IN ANY CASE WHATSOEVER WILL BE THE TOTAL AMOUNT PAID BY YOU TO POLIS IN THE 12 MONTHS IMMEDIATELY PRECEDING THE DATE OF THE HARM IN QUESTION.

8.4 Indemnity.  You shall defend and indemnify Polis and its Representatives against any claim, demand, suit or proceeding made or brought against Polis and its Representatives in connection with your use of the Service, including claims that Polis, the Service, or you: (a) infringe or misappropriate a third party’s intellectual property rights; (b) violate any applicable law, including any failure to obtain the required legal documentation, including applicable consent documentation, prior to using the Service; (c) cause bodily harm or death; (d) violate the terms of a third-party agreement to which you are bound; or (e) commit an act of gross negligence or intentional misconduct.  Your obligation to indemnify Polis and its Representatives arises so long as Polis: (x) promptly gives written notice of the claim against Polis; (y) gives you sole control of the defense and settlement of the claim except that you shall not enter any settlement or disposition that attributes liability or confers a financial obligation on Polis without Polis’s advance written consent, which shall not be unreasonably withheld or delayed; and (z) gives all reasonable assistance, at your expense.

  1.   DISPUTE RESOLUTION

9.1 Initial Dispute Resolution.  Most disputes between you and Polis can be resolved without resort to legal action.  If you have any dispute with Polis, you agree that before taking any formal legal action you will contact us at polis@polis.ac, and provide a brief, written description of the dispute and your contact information.  You and Polis agree to use commercially reasonable efforts to settle any dispute, claim, question, or disagreement directly through consultation, and good faith negotiations shall be a condition to either party initiating a lawsuit or arbitration.

9.2 Binding Arbitration.  If the parties cannot come to a resolution within 30 days after the time an informal dispute resolution is initiated, you agree to that any disputes or claims between you and Polis, including the Representatives, shall be resolved by confidential, final and binding arbitration to be conducted in the Commonwealth of Massachusetts and administered by the American Arbitration Association.  The arbitration shall be commenced and conducted in accordance with its International Arbitration Rules (the “Rules”).  Your arbitration fees and your share of the arbitrator’s compensation shall be governed by and, where appropriate, limited by the Rules.  BY AGREEING TO ARBITRATION, YOU UNDERSTAND THAT YOU ARE WAIVING THE RIGHT TO SUE IN COURT OR HAVE A JURY TRIAL FOR ALL CLAIMS, EXCEPT AS LIMITED BY APPLICABLE LAW.

  1.   GENERAL

10.1 No Joint Relationship /Independent Contractor Relationship.  Nothing in the TOS shall be construed to create any joint partnership, joint venture, employer-employee or agency relationship between you and Polis.  Educators and Polis do not have an employer-employee relationship and Educators are independent contractors who control their own hours, set their own hourly rates, Session Fees and use their own equipment.

10.2 Governing Law.  The TOS and Privacy Policy are governed by the laws of the state of Delaware and the applicable laws of the United States, without reference to principles of conflicts of laws. The parties irrevocably attorn to the jurisdiction of the appropriate state and federal courts of the state of Delaware to hear any proceedings related to the TOS or Privacy Policy.

10.3 Severability and Waiver.  If any provision of the TOS or Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, such provision shall be changed and interpreted so as to best accomplish the objectives of the original provision to the fullest extent allowed by law with remaining provisions of the TOS in full force and effect.  No failure or delay by a party in exercising any right, power or remedy under the TOS constitutes a waiver.

10.4 No Conflicts.  You confirm that by agreeing to the TOS or providing services through Polis, you are not violating the terms or provisions of any other agreement you have with a third party or an applicable teaching restriction policy, which includes, if an Educator, contract terms and any applicable policies with a third-party educational institution such as a university in which you are employed.

10.5 Force Majeure.  Except for any Session Fee payment obligations, neither you nor Polis shall be liable for failure to perform any obligation under the TOS to the extent such failure is caused by a force majeure event (including acts of God, pandemics (including government-imposed recommendations and restrictions due to a pandemic), natural disasters, war, civil disturbance, action by a government entity, strike, and other causes beyond reasonable control).  The party affected by the force majeure event shall provide notice to the other party within a commercially reasonable time and shall use commercially reasonable efforts to resume performance as soon as practicable.  Obligations not performed due to a force majeure event shall be performed as soon as reasonably possible when the force majeure event concludes.

10.6 Assignment.  Polis may assign the TOS without your consent or notice to you.  You cannot assign the TOS.

10.7 Survival.  Sections 2 to 10 survive termination of the TOS.

10.8 Entire Agreement.  The TOS, together with the Privacy Policy and any other Polis documents linked to in this TOS, constitute the entire agreement between you and Polis with respect to the subject matter hereof and supersedes any prior oral or written agreements, communications, representations or undertakings provided.

10.9 Updates.  Polis reserves the right to modify the TOS at any time (each, an “Update”) and shall inform you of each Update.  After informing you of an Update, you are deemed to accept any Update by continuing to use the Service unless you terminate the Service.  Unless Polis states otherwise, an Update is automatically effective 30 days after informing you of such Update.

Privacy Policy

Effective Date: July 28, 2023

This Privacy Policy applies to Polis Educational Solutions, Inc. (“Polis”, “we”or “our”) and its services, including but not limited to providing you access to the Polis’s website and affiliated sub-domains  (the “Website”), the Polis platform, any other product or interactive service to which we apply this Privacy Policy (collectively,the “Service”), and details how we collect, use, and disclose data,including personal data about you and your business (together, “you” or“your”).

AS FAR AS THIS PRIVACY POLICY IS APPLICABLE IN YOUR JURISDICTION, BY CLICKING “I AGREE”OR ANY SIMILAR CONFIRMATION, BY CREATING AN ACCOUNT ON THE SERVICE OR BY USING THE SERVICE YOU ARE AGREEING TO BE BOUND BY THE PRIVACY POLICY.  IF YOU DO NOT AGREE TO ALL TERMS AND CONDITIONS OF THIS PRIVACY POLICY, DO NOT USE THE SERVICE.

  1.   DESCRIPTION OF THE SERVICE

Polis offers an advising management system to institutions and individuals that matches and connects students (each a “Learner”) with top educators (each an “Educator”) for 1:1 virtual advising sessions on its online marketplace.
2. HOW WE OBTAIN PERSONAL DATA

The Service requires the collection and processing of your personal data, which is information about you or that identifies you, which we use to tailor the Service to your educational needs.

Subject to legal, contractual and technical requirements, you may choose not to provide Polis with certain data or request the deletion of certain data, which may impact the essential operation of the Service.3. PERSONAL DATA WE COLLECT

We collect certain personal data when you begin using the Service. The following is a description of the personal data that we may collect, use and process in connection with the foregoing:

· your full name, email address, and telephone number;

· your educational credentials/background and future intended pursuits;

· identity verification information like your Social Security Number, etc.;

· uploaded content and documents, including your resume/CV, photo, materials, etc.;

· session recordings (including any transcriptions and audio-visual recordings of sessions, as well as your face and voice) and other communications made through the Service;

· derivative data, including your country location, IP address, browser type, operating system, access times, and page history;

· personal information via background checks (for Educators);

· payment information, which is collected and processed solely by third-parties (such as Stripe) and to which Polis does not have access;

· mobile device data, including the mobile device’s model, manufacturer, and location, if our website is accessed from your mobile device;

· any information that you share with Polis on social media;

· questions, comments, or other information which you communicate to us via email or phone, or via our internal Inbox chat system;

· answers to feedback surveys, rating/comment requests, questionnaires, intake forms, and inquiry emails (including through SurveyMonkey and SurveySparrow); and

· website analytics, which monitor your use of the Website to better improve the Service.

  1.   HOW WE USE YOUR PERSONAL DATA

We process your personal data for our legitimate business purposes. These uses include but are not limited to:

• creating an account and providing the Service to you, including tailoring the Service to your educational needs based on the data that you provide to Polis;

• for identification and authentication purposes related to the Service;

· understanding your educational needs and improving the quality of the Service, including providing customer support and feedback, providing semi-public ratings and review of Educators, analyzing functionality and technical issues, improving matching algorithms, tracking use of the Service and generating internal reports and data models that we use to improve the Service;

· gaining a better understanding of the Website use and activity;

· contacting you for various reasons concerning the Service such as customer support, transactions, educator recommendations, security and privacy, and administrative issues; and

· for contractual, legal, regulatory or audit obligations, including responding to requests from law enforcement or a government agency asserting lawful authority to obtain the data or where Polis has reasonable grounds to believe the data could be useful in the investigation of unlawful activity. This includes, but is not limited to, complying with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of data, complying with court rules regarding the production of records and data, defending Polis in a legal, regulatory or administrative proceeding or in a contractual dispute or providing information to our legal counsel.

We may need to disclose your personal data to our parent companies, affiliates, subsidiaries, employees and contractors for the same purposes described above.  

  1.   INFORMATION AMONG USERS

Polis provides a minimum amount of personal information between Educators and Learners to match and connect users for virtual advising sessions, including, your first name and last initial, city, photo, and details about the type of office hours help you seek or provide. Messages between Learners and Educators also include their first name and last initial. In the case of user feedback on a session, we will transmit it to users on an as-needed basis to improve the Service.

  1.   THIRD-PARTY SERVICES

Polis does not sell your personal information to third parties. While Polis does not sell personal data with third parties, this Privacy Policy only applies to personal data that Polis collects, processes and discloses and does not apply to the collection, processing and disclosure of data by third parties through third-party services, including Amazon Web Services (AWS), Google Analytics, Squarespace, SurveyMonkey, SurveySparrow, Sharetribe, Twillo, and Stripe, which may be broader than set forth in this Privacy Policy, and that may be embedded into the Service.  

In many cases, third parties may collect personal data about your online activities over time and across different websites and services.  We strongly recommend that you read each third-party privacy policy carefully before using the Service. Please contact us directly using the information found below if you would like to learn more about third-party data practices.

  1.   COOKIES AND TRACKING TECHNOLOGIES

The Service uses tracking technologies, such as cookies and web beacons, to collect data about you, such as your IP address and device information. Currently, the Website uses Google Analytics (which you can opt-out of using your web browser cookie settings) but may use other cookies and tracking technologies in the future, which shall all be listed here. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. Based on this data, third-parties may be able to resolve your identity across multiple devices. This data is collected, used and disclosed in accordance with the terms of this Privacy Policy and the applicable third-party privacy policies. Certain Service features may rely on tracking technologies and by declining to accept cookies or by changing certain settings on your device, you may not have access to these features.

  1.   DATA TRANSMISSION

Polis takes all reasonable measures necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information. Information about Users maintained on Polis’s systems is protected using industry standard security measures and encryption during transmission and at rest. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.

Unfortunately, even with these measures, Polis cannot guarantee the complete security of personal information. By using the Service, you acknowledge and agree that Polis makes no such guarantee, and that you use the Service and Platform at your own risk.

  1.   STORAGE AND USE OF SESSION RECORDINGS AND TRANSCRIPTIONS

Polis records, stores, and uses the recordings and transcriptions of every virtual session between Learners and Educators in the following current ways:

· for determining and recommending personalized educator suggestions;

· monitoring for quality control and safety in virtual sessions;

· providing advising feedback to Educators;

· improving accessibility options for Users;

· carrying out research to develop new products and better improve advising in higher education settings in according to all required laws.

Before the start of every session on the Platform, users must consent to having their session recorded and transcribed in order to use the Service. If any User requests to have their session data deleted, Polis will follow industry-standard protocols for review and deletion and will comply with the request within 90 days if no legitimate reasons remain for preservation of that data after a review.

  1.   OBTAINING, RECTIFYING AND CONTROLLING YOUR PERSONAL DATA

You may contact Polis to obtain a copy of any personal data we collect about you, the production of which may be subject to a fee as permitted by applicable law. In addition, you may contact Polis to correct inaccurate personal data or to complete incomplete personal data.  If you have an account with us, you can access, correct, delete, or modify some of the personal information you provided to us in your account settings.

You may be able to opt-out of some or all of the ways in which your personal data is processed, or request the deletion of certain personal data, except where the personal data is necessary or vital for:

• the performance of contractual obligations, such as the Polis Terms of Service or certain legal obligations;

• protecting your interests or those of another person; and

• our legitimate interests or the legitimate interests of a third-party,

and may do so by requesting deletion by contacting us using the contact information found below.

  1.   DATA STORAGE AND RETENTION

While Polis is a US company, the data you provide through the Service may be stored and processed by third parties in countries around the world. You are aware that Polis is a US company, and you authorize Polis and third parties acting on our behalf to process your data in any country of their choosing, which may cause your data, including personal data, to be subject to privacy protections and legal rights applicable in other jurisdictions.  In all cases, all data you share with Polis will be handled with the utmost care. If you have any questions about the storage and/or security of your personal information, you can contact us at polis@polis.ac.

Polis complies with international personal data transfer laws in applicable jurisdictions. For European Economic Area (“EEA”) residents, Polis complies with Articles 44-49 of the European Union’s General Data Protection Regulation (the “GDPR”).

Your personal data is retained until you request its deletion or until Polis no longer requires such data for the purpose for which it was collected or until required to be deleted by laws applicable in your jurisdiction.. Please email us at polis@polis.ac to delete any personal data of yours that we hold.

  1.   DO NOT TRACK DISCLOSURE

Do Not Track (“DNT”) is a web or device setting that allows you to request that receivers of personal data stop their tracking activities.  When you choose to turn on the DNT setting in your browser or device or use alternative consumer choice mechanisms, your browser or device sends a special signal to websites, analytics companies, advertising networks, plug-in providers and other web services you encounter to stop tracking your activity.  Currently, we do not respond to DNT requests although we have configured Google Analytics to honor DNT signals from your browser.

  1.   CALIFORNIA “SHINE THE LIGHT” RIGHT

If you are a California resident, California Civil Code 1798.83 grants you the right to request disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year.  If you are a California resident and would like to make this request, please contact us using the contact information set forth below. While currently, the California “Shine the Light” law does not apply to Polis as Polis has under 20 employees, if one day, this law does apply to Polis, please note that you may only make this request once per year.

  1.   YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California Civil Code Section 1798.120 permits you to opt-out of the sale and sharing of your personal information to third parties.  Currently, Polis does not sell or share your personal information to third parties and as such no opt-out of the sale or sharing of such personal information is necessary.  Although Polis does not sell or share your personal information to third parties, Polis does provide a general opt-out right to all of our users as described in this Privacy Policy.  If you have any other questions about our privacy practices, please email us at polis@polis.ac.

  1.   RIGHTS OF EUROPEAN ECONOMIC AREA RESIDENTS

Polis has a lawful right, as described in Article 6(1)(b) of the GDPR, in collecting your personal data as described in section 3 of this Privacy Policy for the purposes described in detail in section 4 of this Privacy Policy, as this personal data is necessary to provide the Service to you, including verification of your educational details and in order to match you with appropriate Educators.  In addition, when you provide consent to contact you using your email address or phone number, Polis may contact and communicate with you using this information, pursuant to Article 6(1)(a) of the GDPR.

If you are a resident of the European Economic Area, you have certain rights in regard to your personal data.  These rights include:

● A Right of Access.  You have the right to access your personal data that we hold about you free of charge in most circumstances;

● A Right to Rectification.  If your personal data is inaccurate or incomplete, you can change the information you provided by changing the information yourself on your Account or by contacting Polis using the email listed below;

● A Right to Erasure.  You have the right to obtain deletion of personal data concerning you in many cases. Often you can just delete your information by yourself through your Account, but you can also request the deletion by using the contact information found below.  Please be careful as the deletion of your data in this manner is permanent and may never be restored;

● A Right to Object.  If the processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR or consent based on Article 6(1)(a), you have the right to object to this processing in most cases.  If you object to Polis’s processing of your personal data, we will no longer process your personal data unless permitted by the GDPR; in particular if the personal data is necessary for the establishment, exercise or defense of legal claims or in the case where the personal data is required for the provision of certain features of the Service, and you still wish to use such features of the Service that require the processing of the personal data to which you objected to;

● A Right to file a Complaint.  You have the right to file a complaint with the appropriate supervisory authority in your jurisdiction;

● A Right to Restriction of Processing of your Personal Data.  You have the right to obtain restrictions on the processing of your personal data as described in Article 18 of the GDPR;

● A Right to Personal Data Portability.  You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller under the conditions described in Article 20 of the GDPR. Although the personal data collected by Polis is not particularly useful to other companies as the data collected largely relates to your usage of the Service, Polis will comply will all requests for the portability of your personal data;

● A Right to Post-Mortem Control of Your Personal Data.  If data protection legislation and related regulations in France are applicable to you, you have the right to establish guidelines for the preservation, the deletion and the transmission of your personal data after your death in accordance with Article 40-1 of the Act No. 78-17 of January 6, 1978 on Information, Technology, Data Files and Civil Liberties; and

● A Right to Opt-out of Marketing Communications.  You have the right to opt-out of marketing communications we send you at any time even if you have previously consented to such communications.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link on any marketing e-mails Polis sends you.  To opt-out of other forms of marketing, please contact us using the contact details provided below.

  1.   CHANGE OF OWNERSHIP OR BUSINESS TRANSITION

In the event of, or in preparation for, a change of ownership or control of Polis or a business transition such as the sale of some or all Polis’s assets, we may disclose and/or transfer your personal data to third-parties who will have the right to continue to collect and use such data in the manner set forth in this Privacy Policy.

  1.   SECURITY

We are committed to ensuring that your data is secure.  To prevent unauthorized access, disclosure, or breach, we have put in place suitable physical, electronic, and administrative procedures to safeguard and secure the data we collect and process, including appropriate protections for any sensitive personal data we collect.

  1.   CONTACT PREFERENCES

We will communicate with you through your email address, phone or other digital methods in order to conduct the Service and to respond to support requests or comments.  If you have provided us with your email address and would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within certain types of emails that we send to you or, if no link is available, by replying with “unsubscribe” in the email title or body.  On rare occasions, some types of email are necessary for the Service and cannot be unsubscribed from if you continue to use the Service.

  1.   AGE REQUIREMENT

All users must be 18 years or older to use Polis and comply with our Terms of Service. The Service is not intended for anyone under that age or is considered a minor. Polis does not willingly collect personally identifiable information about and from minors. Please contact us if you have any questions at polis@polis.ac.

  1.   UPDATES

Polis reserves the right, in its sole discretion, to modify this Privacy Policy at any time (each an “Update”) and shall make each Update available on our website. You are deemed to accept an Update by continuing to use the Service. Unless Polis states otherwise, an Update is automatically effective 30 days after posting on the website, except in such case where an Update is immaterial to any of your legal rights or legal obligations of Polis and such Update is made only to correct a typographical, formatting or grammar inaccuracy, and in such case, an Update is effective immediately after posting on the website.

  1.   CONTACT US

If you have requests, questions or comments about the Privacy Policy or our data collection in general, please contact our Chief Technological Officer or our Privacy Team at polis@polis.ac or at the following address:

Polis Educational Solutions, Inc., 1 Mifflin Square, Suite 400, Cambridge, MA 02138 USA

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Educational Policy

As an educator-run private company, we hold ourselves as well as our users and affiliates to the highest professional and ethical standards for educational integrity.

Each registered user - learner and educator – on our platform accepts our Term of Service when signing up and creating an account. By doing that, every user must respect the academic trademarks of universities and college with which our educators are currently or were affiliated as students,alumni, and/or faculty.  

Moreover, users on Polis agree to be familiar with and honor any academic integrity or honesty policy, outside activity policy, and any related policies required of them as faculty, students, and alumni/ae.Educators and learners are responsible for understanding their own institutions’ policies and ensuring that their activities on Polis comply with their institution’s policies. Polis will not under any circumstances knowingly ask educators to violate such policies but is not responsible for checking users’ compliance with their own institutions’ policies. Users must inform us of all potential issues or changes in policy.

As a private company, Polis affirms that it has no academic degree-granting affiliation with any university or educational institution. Whether on or off the Polis platform, registered learner and educator users will not engage in any exchange that involves preferential treatment in admissions, forced writing of letters of recommendations, the completion of writing or assignments (e.g. plagiarism), or any form of academic dishonesty. This principle applies to any offer or request that would run contrary to the academic, admissions, and conduct policies of any academic institution which users are or may be affiliated with.

Finally, Polis reserves the right to limit, deny,or terminate access to our platform to users who do not abide by our Terms of Service and this policy. We also reserve the right to be the final arbiter of what consists of educational integrity on our platform. If necessary, we will seek legal and financial remedies for any damages caused to our company, our partners, and our community of users for any intentional and malicious undermining of our Terms of Service, Privacy Policy, and this policy.

If you have any questions about our policy,please contact us at polis@polis.ac.