Privacy Policy for Nearo

2. Personal Data We Collect

a. Information You Provide

We may collect personal data you provide directly, including:

• Name
• Email address
• Account login credentials
• Billing and payment information (handled by third-party payment providers)
• Communications with Nearo (such as support requests or feedback)
• Any content you choose to share while using the Service

b. Information Collected Automatically

When you use Nearo, we may automatically collect:

• IP address
• Device type, browser, and operating system
• Usage data (such as session activity, timestamps, and feature usage)
• Log data and diagnostic information

c. Audio, Video, and Screen Data

Nearo provides real-time audio, video, screen sharing, and remote control functionality.

• Nearo does not record sessions by default
• If recording is enabled, the user enabling recording is responsible for obtaining any required consent
• Audio, video, and screen-sharing data are processed in real time to provide the Service and are not stored unless explicitly configured

d. Guest Users (No Account Required)

Nearo allows individuals to join sessions without creating an account ("guests").

For guest participants, we may process limited data necessary to operate the Service, including:

• IP address
• Device and browser information
• Real-time audio, video, and screen-sharing data during sessions

Nearo does not require guests to create an account and does not attempt to identify guests beyond what is necessary to provide the Service.

3. Session Participation and Responsibility

Nearo enables users to invite others to join sessions via shared room links.

• Participants may join sessions as registered users or as guests
• The session host (e.g., tutor, educator, or organization) controls who is invited and admitted
• The session host is responsible for ensuring appropriate permissions and consents are obtained

Nearo processes session data solely to establish and maintain sessions and does not use guest data for independent purposes beyond providing the Service.

4. Legal Bases for Processing (GDPR / UK GDPR)

We process personal data under the following legal bases:

• Contractual necessity: To provide and operate the Service
• Legitimate interests: To maintain and improve the Service, including security and performance
• Legal obligations: To comply with applicable laws and regulations
• Consent: Where required, such as for certain communications

When acting as a Data Processor, Nearo processes data according to instructions from the applicable Data Controller.

5. How We Use Personal Data

We use personal data to:

• Provide, operate, and maintain Nearo
• Enable real-time communication and tutoring sessions
• Process payments and manage subscriptions
• Provide customer support and respond to inquiries
• Monitor for security, fraud, and abuse
• Analyze usage to improve functionality and user experience

6. Educational Use and FERPA

Nearo is used in educational and tutoring contexts.

When used by schools or educational institutions:

• Nearo acts as a service provider ("school official") under FERPA
• Nearo processes student data only at the direction of the educational institution or educator
• Nearo does not sell student data
• Nearo does not use student data for advertising or profiling
• Nearo does not claim ownership of student data

Educational institutions and educators are responsible for:

• Providing required privacy notices
• Obtaining parental or student consent where required
• Managing who is invited to sessions, including guest participants
• Determining appropriate data retention practices

7. How We Share Personal Data

We do not sell personal data.

We may share personal data with:

a. Service Providers

Third-party providers that support operation of the Service, including:

• Hosting and infrastructure providers
• Payment processors
• Analytics and monitoring tools
• Customer support platforms

These providers are contractually limited to using data only to provide services to Nearo.

b. Legal Requirements

We may disclose personal data if required by law or in response to valid legal requests.

c. Business Transfers

If Nearo is involved in a merger, acquisition, or asset sale, personal data may be transferred as part of that transaction.

8. International Data Transfers

Personal data may be processed in countries outside your jurisdiction, including the United States.

Where required, we use appropriate safeguards, such as:

• Standard Contractual Clauses (SCCs)
• Equivalent UK transfer mechanisms

9. Data Retention

We retain personal data only as long as necessary to:

• Provide the Service
• Fulfill legal obligations
• Resolve disputes
• Enforce agreements

When Nearo processes data on behalf of an educational institution, retention is determined by the institution (as Data Controller).

10. Data Security

Nearo implements reasonable administrative, technical, and organizational measures to protect personal data.

However, no method of transmission or storage is completely secure.

11. Your Rights

Depending on your location, you may have rights to:

• Access your personal data
• Correct inaccurate data
• Request deletion of your data
• Restrict or object to processing
• Request data portability
• File a complaint with a supervisory authority

If Nearo processes your data on behalf of an organization, we may direct your request to that organization.

12. Children's Privacy

Nearo does not knowingly collect personal data directly from children under 13 outside of an educational context.

Students may use Nearo under the supervision of a tutor, educator, or institution, including as guest participants.

13. Cookies and Analytics

Nearo uses cookies and similar technologies to:

• Maintain session functionality
• Understand usage patterns
• Improve performance and usability

You can control cookies through your browser settings.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted with a revised effective date.

Your continued use of the Service constitutes acceptance of any updates.

15. Contact Information

If you have questions about this Privacy Policy or our data practices, contact us at:

Email: support@getnearo.com