Last Update: November 1, 2020

We are delighted that you have come to our web site, operated by Jugaad Ventures Inc. in Vancouver, British Columbia, Canada.

Simbi™ is our online software application learning platform (“Simbi™” and the “Application”) designed for use with educational institutions and their learners. Simbi™ is part of a curriculum program which we believe helps improve learning outcomes in literacy through a reading app we developed.

This Privacy Policy, when accepted in accordance with the provisions which follow below, form an agreement (the “Agreement”, as further defined below) between JUGAAD VENTURES INC., a company formed under the laws of British Columbia, Canada (“Jugaad”, “us”, “our”, and “we) and the Person accessing our Application (the “User”, “Subscriber”, or “you”).

This Privacy Policy will apply to the use of our Website located at and the use of the Application and any other applications, online services, or features we may offer from time to time to you at or via our Website (together, the “Services”).

Protecting your privacy and the privacy of all our users is fundamental to our mission and business.

The following summarizes our commitments to you:

  • We never sell your personal information.

  • We don’t own the content you add to Simbi.

  • We securely store your personal information within Canada.

  • We use the latest security industry best practices to protect you.

  • We are transparent about our practices and will notify you if things change.

This Privacy Policy governs the collection, use and disclosure of personal information through our website,, any subdomains thereof, and any successor websites, and the Simbi online software application learning platform (the “Service”.

This includes personally identifiable information that we collect when you create an account (“Account Information”), and content added to the platform (“Content”).

Person Information means any information relating to an identifiable individual. By using the Service, you agree to this Privacy Policy. If you don’t agree, please don’t use the Service. You can contact our Privacy Officer anytime with questions about this Policy at [email protected].

What personal information do we collect?

  • Contact information. In order to open an Account, we ask for an email address (of a parent or guardian of a student who is under 13 years of age, or of a teacher or educator).

  • User name and password for account creation. If you create an Account, we may collect a user name and password. In order to help teachers, educators, parents, or guardians identify a particular student or learner user, we may also collect a student’s first name and grade level if provided in order to best customize their use of our Service.

  • Your content. We also collect Content that is added by users of the Service. This Content is generally made up of voice recordings, of learners, students, parents, guardians, teachers and educators.

  • Your self-identified accent type to accompany any content, such as voice recordings, that you add to the Service.

  • Correspondence you send to us. We may store correspondence with students, learners, parents, guardians, educators, or teachers related to our Service, and we may collect any personal information that you send to us via email or otherwise.

  • Log Data: When you use the Service, we receive log data such as your IP address, browser type, operating system, device information, and your mobile carrier. In addition, we may receive or collect additional information such as the referring web page, referring search terms, and pages visited.

We do not collect...

  • Student educational records;

  • Information that directly identifies a child (such as full name, e-mail address (unless provided for account notifications by an educator, teacher, parent, or guardian), phone number); or

  • Personal information of a child, unless we have obtained a parent or legal guardian's consent or otherwise comply with law.

Any user of the Service must be able to provide consent – with respect to use of the Service and how we collect, use and disclose personal information. We require that educators obtain parental consent before using Simbi with children who are under the age when they can legally grant consent on their own.

In Canada and the US, if you are under age 13, you need to make sure a parent or guardian is reading and consenting to this Policy as well as the Terms of Use on your behalf. You should check your local laws to determine the relevant age in your country.

We do not knowingly collect any personal information from anyone under 13 years of age without parental consent. If you are aware that we are collecting information from a child without parental consent, please contact us immediately at [email protected] and we will delete the information.

For your convenience, here is a link to our Parent/Guardian Consent Form:


The purposes for which we collect your information, the categories and specific types of information, and our practices and policies regarding the processing of your information are described in this Privacy Policy and our Data Processing Addendum available at

How do we use your personal information?

We only use the personal information that we collect to provide our Service to you. For example, we use this information to:

  • Allow you to access and use our Service by verifying your identity and storing your Content.

  • Create and share narrated books using voice recordings.

  • Provide students, learners, educators, teachers, schools, parents, guardians, and family members with customer support.

  • Notify you about activity on and updates to your account or your child’s account (if you’ve indicated in your account settings that you’d like notifications).

  • Research, understand, and analyze trends of users to improve and develop new features for our products.

  • Invite your contacts, friends, family, and acquaintances to read with you via social sharing and internal sharing services.

  • Allow you to be add users, and be added, to groups for use at home, at school, and elsewhere.

  • Provide authorized teachers, schools, parents and family members with progress regarding their students’, or child’s, or children's account.

  • Promote new products and services to teachers, parents and schools.

  • Investigate, prevent, and detect activities on our service that we believe may violate the law or applicable regulations. We may, at the request of a school, investigate accounts to determine whether they comply with school policies.

  • If you are using the Service as a teacher, parent, or educator, we may use your IP address to determine your approximate location for the purposes of sending you customized marketing and other information about our products.

  • Provide information to your school, school district, or educational organization regarding your usage of our Service. If you are a minor using our Service, information regarding your usage may be made available to teachers, educators, or parents that have access to your account.

How do we use cookies?

Cookies are small text files that we transfer to your web browser that allow us to identify your web browser and store information about your account. We use these cookies to keep you logged in to the Service, customize your experience, understand how you use the Service, and promote the Service to relevant teachers and schools.

You can choose to remove or disable cookies via your browser settings. Please be aware that the Service may not work as intended or at all if you disable or decline cookies.

Do we allow advertising or share personal information for advertising?

No. We do not display ads, allow third-party ads, share information for the purpose of displaying ads, or allow information collection by third-party advertisers or data brokers.

In what circumstances may we share personal information?

We do not sell or share the personal information you provide to us with third parties except in the limited circumstances detailed below, and as otherwise described in this policy:

  • We use a small number of third-party service providers in order to operate and improve the Service – for example a data centre operator that manages our servers or a notification service that helps us send you messages about your account. These services need access to your personally identifiable information in order to work (i.e. your email address is required to send you email), but are contractually prohibited from using that information for any other purpose other than to provide the Service.

  • We may disclose your information to a third party to comply with applicable laws or regulations, or a valid legal request - including to meet national security or law enforcement requirements. If we are going to disclose your personal information, we will do our best to provide you with notice in advance by email, unless we are prohibited from doing so by law.

  • We may disclose or transfer your Account Information and Content in connection with the sale, merger, bankruptcy, sale of assets or reorganization of our company. We will notify you if a different company will receive your information. This Privacy Policy will apply to your personal information as transferred to the new entity.

Your personal information is securely stored within Canada:

All of our Service's production servers are located in Canada. Our web and database servers are physically located in Amazon Web Service's Montreal data centre and our static files such as audio and images physically located in Google Cloud Platform's Toronto data centre.

Do we work with third-party analytics services?

We are constantly improving, and we use aggregate data about how the Service is used - for example what buttons you click on or what pages you visit - to inform those decisions.

To help us analyze this data, we use a small number of third-party services (such as Google Analytics, Mix Panel, Segment, Facebook, Roll Bar, and Intercom).

In no circumstances is any personal information you have shared with us shared with these services. In addition, these services are contractually obligated only to use information about your usage of the Service to provide analytics services to us and are prohibited from sharing it or using it for other purposes.

If you do not wish to participate in Google Analytics, you may download the Google Analytics opt-out browser add-on.

Retention of your personal information:

We will only retain personal information for as long as necessary to achieve the purposes outlined in this Policy. Note that we may delete an account and all Content associated with the account if the account has not been accessed for more than 2 years.

How to view, correct, edit, or update your personal information:

If you would like to access, correct, edit or update any of your personal information, you can do this by logging into your Account, or by contacting our Privacy Officer at [email protected]

How to delete your Simbi account:

If you would like to delete your Simbi account or any content submitted through the Service, please send an email to [email protected].

Bound by the logic of our relation database, voice recordings are immediately made unavailable and their static files, such as voice recording sound files, are subsequently deleted within 24 hours when any remaining cached data is flushed by our servers upon a user's account deletion.

How do we keep your personal information safe?

We take protecting your security and privacy seriously and we've put a number of measures in place to protect your personal information, including the use of secure socket layer (SSL) technology to transmit your data.

In the event of a security breach, we will notify affected account holders within the amount of time required by law so that you can take steps to keep your personal information safe.

Changes to our Privacy Policy:

We may from time to time, make changes to this Privacy Policy to account for changes to our practices or applicable law. If we make changes to this Privacy Policy that we believe will materially affect your rights, we will notify you by email about these changes and post a notice to our service. If you continue to use our service after you receive notice of changes to this Privacy Policy, you will accept these changes.

Our Contact Information:

If you, or an individual or organization that you assist in accessing Simbi, have any questions or comments regarding our Privacy, please reach out to us at [email protected]. You can reach Simbi by mail at: 700 W 16th Avenue Vancouver, British Columbia V5Z 1S7, Canada.

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