Privacy Policy

Forte Privacy Policy

Effective as of April 26, 2023.

Please click here to view the previous version of our Privacy Policy.

This Privacy Policy describes how LessonHome, Inc. d/b/a Forte (“Forte” “we“, “us” or “our“) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)).

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.

Frequently Asked Questions

We know that you care about how your personal information is used and shared. We have tried to include as much information as possible in this Privacy Policy to help you better understand our data processing activities. These FAQs are designed to provide a ‘snapshot’ of the relevant information we think our users are most likely to be interested in.

What is Forte?

Forte provides a web-based communications platform that allows students (“Students”) to receive music lessons (“Lessons”) from music teachers (“Teachers”), including Teachers certified by educational institutions and conservatoires (“Institutional Partners”), improving access to quality musical education.

What personal information do we collect?

We collect personal information that you provide us and that we need to provide the Services. For example, if you are a Teacher, we need to know your professional background and the instrument(s) you play so that we can pair you with a relevant Student. Similarly, if you are a Student, we need to know your instrumental skill level so that we can find Teachers that work best with learners of your skill level. We may also collect other personal information in the course of business, such as technical information about your device (e.g., operating system).

Why do we collect your personal information?

We do not obtain any monetary consideration from sharing or selling your personal information with any outside party.

We connect Students with Teachers to optimize Students’ learning outcomes. We use Students’ personal information to find Teachers that may be best placed to help Students meet their learning goals for their chosen instrument(s) and level of experience. If you request Lessons from a Teacher, we will share some of your personal information with that Teacher to facilitate the Lessons. We host Lessons on our purpose-built web-based communications platform. We also use your personal information to run our business (e.g., for marketing purposes) and to improve our Services (e.g., by performing analytics).

Who do we share your personal information with?

Like most companies, we share your personal information with third parties that help us provide our Services (e.g., website hosting providers, payment processors). We may also share your personal information in particular corporate contexts (e.g., if our company is being sold, or if we have to provide certain data to our insurers). If Students elect to take a Lesson with an Institutional Partner, we may, with the Student’s consent, share information about the Student with the relevant Institutional Partner. Our current Institutional Partner is the Royal College of Music. For more information, please see the How we share your personal information section.

For more information, please see the further detail in this Privacy Policy or contact us.

Index

Personal information we collect
How we use your personal information
How we share your personal information
Your choices
Other sites and services
Security
International data transfers
Children
Changes to this Privacy Policy
How to contact us
Notice to European users

Personal information we collect

Information you provide to us. Personal information Students and Teachers may provide to us through the Service or otherwise includes:

Student contact data, such as a Student’s first and last name, salutation, email address, billing and mailing address, and phone number.
Parent contact data, such as a Student’s parent’s first name and last name, email address, billing and mailing addresses, and phone number.
Teacher contact data, such as a Teacher’s first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
Student user data, such as the username and password that a Student may set to establish an online account on the Service, date of birth, biographical details, instrument(s), photograph or picture, interests, preferences, instrumental skill level, experience and learning goals, information about a Student’s participation in our contests, promotions, or surveys, and any other information that Students choose to provide.
Teacher profile data, such as the username and password that a Teacher may set to establish an online account on the Service, professional background and credentials, instrument(s), photograph or picture, interests, preferences, hourly service rates, ratings and reviews from Students, studio demographics, information about your participation in our contests, promotions, or surveys, and any other information that you add to your profile.

We may also process the following information:

Demographic data, such as your city, state, country of residence, postal code, and age.
Communications data based on our exchanges with you, including when you contact us through the Service or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata, including audio and video recordings of Lessons. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
Promotion data, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your contact data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Other users of the Services, such as Students who submit a review of a Teacher.
Private sources, such as our Institutional Partners where a Student elects to take Lessons officially certified by our Institutional Partners.
Marketing partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

provide, operate and improve the Service and our business, including by facilitating Lessons and matching Students with Teachers;
personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
establish and maintain your user profile on the Service;
facilitate social features of the Service, such as by identifying and suggesting connections with other users of the Service and providing chat or messaging functionality.
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
communicate with you about events or contests in which you participate;
understand your needs and interests, and personalize your experience with the Service and our communications; and
provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

Marketing and advertising. We (or service providers) may collect and use your personal information for marketing and advertising purposes:

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Events, promotions and contests. We may use your personal information to:

administer promotions and contests
communicate with you about promotions or contests in which you participate
contact or market to you after collecting your personal information at an event

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Retention. We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. For example, where a Student has elected to take a Lesson with an Institutional Partner, we may, with the Student’s consent, share information about the Student with the relevant Institutional Partner to allow the Student to receive relevant advertising from the Institutional Partner. Our current Institutional Partners include The Royal College of Music.

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Forte, financing of Forte, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Forte as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Your profile and other user-generated content data (except for messages) are/may be visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Privacy settings. We enable Teachers to determine the visibility of their public-facing profile on the Services.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the information provided in the Notice to European Users section about transfer of personal information outside of Europe.

Children

A Student under the age of 13 (“Child User”) may only use the Service with the express prior consent of a parent or legal guardian. Where we know there is a Child User, then at registration, we will require that you provide your first name and your parent’s or legal guardian’s valid email address. Prior to collecting any additional information about you, we will send your parent or legal guardian a notification email stating that you have requested to create an account on the Service and provide a link to this Privacy Policy. We will also use your parent’s or legal guardian’s email address to let your parent or legal guardian know about any changes to our Privacy Policy. Your parent or legal guardian may at any time review, change and/or delete any information that we have collected about you by emailing help@fortelessons.com.

If you are a parent or guardian of a Child User from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a Child User without the consent of the Child User’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Parents may withdraw consent upon request. Parents and legal guardians can request deletion of a Child User’s information by contacting us.

How does a Child User access the Service?

Child Users access the Service by registering for an account on our Service.

What information about Child Users is visible to others?

No Child User’s information is made available or visible generally to the public through the Service. A Child User’s parent or legal guardian can review and access their Child User’s personal information by [contacting us via email/logging into their connected account].

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

Email: help@fortelessons.com help@fortelessons.com
Mail: Forte, c/o The Greatest Works Agency, 450 Park Avenue South, 3rd floor, New York, NY 10016

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the EU General Data Protection Regulation (“EU GDPR”) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”). Essentially, “personal data” means information about individuals from which they are either directly identified or can be identified.

Controller. Forte is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

Our Representative in the EU. Our EU representative appointed under the EU GDPR is EDPO. You can contact them:

By email to: privacy@edpo.com
By postal mail to: Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Our Representative in the UK. Our UK representative appointed under the UK GDPR is EDPO. You can contact them:

By email to: privacy@edpo.com
By postal mail to: Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’.

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Student contact data Parent contact data Teacher contact data Student profile data Teacher profile data Demographic data Communications data Transactional Data User-generated content data Data from Third Party Sources Device data	Contractual Necessity
Security	Student contact data Parent contact data Teacher contact data Device data Online activity data	Compliance with Law Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks
Research and development	Student contact data Parent contact data Teacher contact data Demographic data Communications data Student profile data Teacher profile data Device data Online activity data	Legitimate Interests. We have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences. Consent, in respect of any optional cookies used for this purpose.
Direct marketing	Student contact data Parent contact data Teacher contact data Demographic data Student profile data Teacher profile data Communications data Transactional data Marketing data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Events, promotions and contests	Promotion data Student contact data Parent contact data Teacher contact data Demographic data Student profile data Teacher profile data Communications data	Contractual Necessity to administer the promotions and contests in accordance with the terms or rules thereof (including communicating with you as and where necessary) In respect of promoting these promotions and contests: Legitimate Interests – we have a legitimate interest in promoting these promotions and contests, including associated publicising of our business and operations. Consent – in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given promotional communications.
Events, promotions and contests	Any and all data types relevant in the circumstances	Legitimate interest. We have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations). However, we would always look to take steps to minimize the amount and sensitivity of any personal information shared in these contexts where possible and appropriate.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law Legitimate interest. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety.
To create aggregated, de-identified and/or anonymized data	Any and all data types relevant in the circumstances	Legitimate interest. We have legitimate interest in analyzing the use of our Service and aggregating, de-identifying and/or anonymizing your personal information for this purpose.
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Other info

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information,
Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to help@fortelessons.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator is below:The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, Institutional Partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).
- However, in these cases:
  - we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or
  - in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.