Legal

GOMME PRIVACY POLICY

Last Updated: June 2025

Gomme Inc. (“Gomme,” “we,” “us,” “our”) respects your privacy. This privacy notice (“Privacy Notice”) has been adopted on a company-wide basis to guide how we process the information that you provide to us through the Gomme website, our user portal accessible through www.getgomme.com, and services accessible through the user portal (collectively, the “Services”). Capitalized terms not otherwise defined herein have the meaning given such terms in our terms of service.

This Privacy Notice does not apply to apps, websites, products, or services provided by companies that we do not own or control or to individuals that we do not employ or manage.

This Privacy Notice does not apply to any personal information you share with your Tutor or your Student outside of the Services. You must use your own discretion when sharing personal information about yourself or anyone else with your Tutor or Student.

Protections provided for processing of personal information do not apply to information that does not relate to an identified or identifiable individual or to personal information or data rendered anonymous in such a manner that the individual is not or no longer identifiable, (“Anonymized Information”). We may process Anonymized Information for our own purposes in any manner and without attribution or compensation to any person.

We reserve the right to change, modify, add, or remove portions of this Privacy Notice. We will post notice of modifications to this Privacy Notice on this page. You must check this page periodically for changes. Changes will become effective immediately but will not apply retroactively. If you do not agree to the modified Privacy Notice you should immediately discontinue your use of the Services.

Lawful Basis for Processing

Many jurisdictions require that we disclose to you the lawful basis for our processing of your personal information. We do that throughout this Privacy Notice. In general, our lawful basis for processing your personal information is based on your specific consent or your contract with us.

By accessing or using any of the Services or by otherwise interacting with us online, you consent to our processing of your personal information as described in this Privacy Notice. If our processing of your personal information is based on your consent, you may withdraw your consent at any time, and we will cease processing your personal information. However, in some cases, this may result in your inability to receive partial or full access to the Services, and your withdrawal of consent does not limit our ability to process Anonymized Information for use by us in connection with our legitimate business efforts in the future. In addition, your withdrawal of consent does not prevent us from processing personal information if we are required to do so by applicable law or to preserve legal claims. It also doesn't prevent us from processing personal information that is processed pursuant to a different lawful basis. For example, if you give your consent for us to process your personal information, but we are also required by law to keep your personal information, that separate “lawful basis” will still apply, even if you withdraw your consent.

When you enter into an agreement with us, either by accessing the Services, by executing an agreement in hard copy or by clicking “I Accept” or similar language online, we will process your personal information for the purposes of fulfilling the terms of our contract with you. In that case, our processing of your personal information is based on the contract, so your withdrawal of consent will only be effective after the purposes for processing that personal information have been fulfilled and after we no longer have a legal obligation to keep that personal information.

In all cases, we will comply with applicable law and we will cease processing your personal information after the legal right, obligation, or other lawful basis expires.

Information We Process

We collect the following types of information from you:

a. Information You Provide:

• Name and contact information (email, phone)
• Photos
• Educational level and curriculum
• Tutoring requests (subjects, schedule, location)
• Profile details for Tutors, including resume/CV
• Career information (companies worked for, roles, positions held, awards, other achievements)
• Additional information about your career, educational or other life background, goals, and plans
• Payment and billing info

b. Information We Process Automatically: Whenever you access or use the Services, we may automatically process information, some of which may constitute personal information, from your web browser, which may include: the device you use to access or use the Services, your IP address, platform types, preferences you submit and preferences that are generated based on the data you submit, and number of clicks.

Why Process Your Personal Information

We use personal information to:

• Match Students with relevant Tutors
• Operate and improve our services
• Notify you of new activity (e.g., tutor applications or student selections)
• Provide support and resolve issues
• Process payments (for Tutors)
• Send platform updates or marketing (if you opt in)
• Ensure user safety and prevent misuse
• Develop anonymized insights for platform improvement
• To train, refine, or develop artificial intelligence models

We may use anonymized data (not tied to individual users) for analytics or internal research. Anonymized data is not considered personal information.

When We May Disclose Your Personal Information

We only share your personal information when necessary and in specific, limited ways:

With other users (for matching purposes): When a Tutor applies to a Student's request, that Tutor's profile is shared with that specific Student. Tutor profiles remain private to all others.

Likewise, a Student's contact information is only shared with the Tutor they choose to work with.

With trusted service providers: We may use third parties to process payments, send emails, or provide analytics. These parties only access your data to the extent needed to perform their role.

With legal authorities: If required by Lebanese law, we may disclose your information to comply with legal obligations, court orders, or to protect GOMME's rights or user safety.

Business Transfers: In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal information may be among the assets transferred. Any acquirer of our assets may continue to process your personal information as set forth in this Privacy Notice.

Cookies and Analytics

We may use cookies or tracking tools to understand how users interact with the platform and improve performance.

You can manage cookie preferences through your browser. Disabling cookies may affect some functionality.

Data Security

We take reasonable steps to protect your personal information, including encryption and secure access controls. However, no system can guarantee full security. You use the platform at your own risk and are responsible for keeping your account credentials secure.

Your Rights Regarding Your Data

You have the right to:

• Access, update, or delete your personal data
• Request that we stop using your data for marketing
• Withdraw your consent (this may limit access to services)
• Request that your account be deleted entirely

To make any of these requests, email us. We will respond as soon as reasonably possible.

Children's Privacy

GOMME is not intended for children under 13. We do not knowingly collect data from anyone under this age. If we learn that we have collected personal data from a child, we will delete it immediately. If you are a parent or guardian and believe this has occurred, please contact us.

Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page and become effective immediately. If changes are significant, we may notify you by email or within the platform.