Elice Privacy Policy

Privacy Policy

Effective Date: May 9, 2025

This Privacy Policy describes how Elice Academy US's online education platform (the 'Platform,' 'we,' 'us,' or 'our') collects, uses, shares, and protects personal information of individuals ('you' or 'users') who visit our website, use our mobile applications, or otherwise interact with our services (collectively, the 'Services'). It also explains your rights and choices regarding your personal information. This Privacy Policy applies to all users of our Services, including students, parents/guardians, and instructors. By using the Services, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the Services. This Privacy Policy is incorporated into our Terms of Use governing your use of the Platform.

Please note that this policy does not apply to information related to our employees, job applicants, or independent contractors, which are addressed under separate policies. We are committed to protecting your privacy consistent with U.S. law, including federal and state regulations. We do not knowingly solicit or collect information from children under 13 without parental consent (see the Children's Privacy section below for more details).

Information We Collect

We collect various types of information from and about you in order to provide and improve our SAT preparation Services. The categories of information we collect depend on how you interact with our Platform. Below we explain the types of information we collect:

1. Information You Provide to Us

You may choose to give us personal information directly when you use our Services. This includes:

Contact and Account Information: When you create an account or inquire about our Services, we collect information such as your name, email address, telephone number, mailing address, login username, and password. If you are a parent or guardian signing up on behalf of a student, we may also collect your relationship to the student and the student's name and age.
Educational and Profile Information: In the context of our SAT prep platform, you might provide details such as the name of your school, your current grade level, expected graduation year, academic interests, and any test scores or academic goals (e.g. prior SAT/ACT scores or target scores). You may also provide other personal or educational content, such as essays, study preferences, or other information to customize your tutoring or coursework. If our Platform offers user profile pages (for example, for tutors or students in study groups), any information you choose to include in your profile (such as a biography, photo, credentials, or interests) will also be collected.
Payment and Financial Information: If you make a purchase (for example, enrolling in a course or buying tutoring hours), we or our third-party payment processor collect payment information. This may include billing name and address, credit or debit card number and expiration date, or other financial account data. For security, we do not store full payment card numbers or sensitive authentication data; payments are handled via compliant payment processors. If you are an instructor, tutor, or other educational contractor who receives payments from us, we collect financial information needed to pay you (such as your bank account details or taxpayer identification number (e.g., Social Security Number or EIN)) and any necessary tax documentation. We use this information only to process payments and comply with legal obligations (like tax reporting).
Communications and Submissions: We collect the content of any communications you send to us. For example, if you email us, call customer support, fill out a form on our site (such as a contact form, survey, or support request), or participate in a live chat, we will collect your name, contact details, and the content of your message. If you submit feedback, testimonials, or responses to surveys or assignments, or if you participate in student forums or discussion boards on the Platform, we collect what you submit. This also includes any files or documents you upload to the Platform (for instance, practice essays for review or other homework submissions).
Tutoring Sessions and Class Activities: If you engage in live tutoring sessions, classes, or practice tests through the Platform, we may collect information related to those activities. For example, we may record video or audio of online tutoring sessions or live classes for quality assurance, training, or to make the recordings available to students for review. We may also keep transcripts or chat logs of tutoring sessions, as well as records of your practice test results, quiz scores, progress tracking, and other performance data that you or your tutor input into the Platform. This information helps us personalize your learning experience and monitor progress.
Referral Information: If you use any refer-a-friend feature we offer, we collect the friend's email address or contact details that you provide in order to send them a one-time referral invitation. We use this information only to send the invitation and do not retain it for other purposes (unless the referred person engages with our Services). By providing a friend's email for referral, you confirm that you have permission to do so.
Job Applications and Tutor Onboarding: If you apply to work with us as an employee or contract as a tutor/instructor (collectively, 'Professionals'), you may provide additional personal information. This can include your resume/CV, employment and education history, qualifications and certifications, references, and other background information. We may also ask for information necessary for background checks or identity verification in compliance with law (such as date of birth, Social Security Number, government-issued ID, or consent for a background check). Any background check reports are typically obtained through authorized third-party providers, and we do not store your sensitive background check details on our systems---just the results needed for our decisions. Information collected in the application or onboarding process will be used for evaluating your application and, if you contract with us, for establishing and managing our working relationship.

Please Note: You are not required to provide personal information to simply browse our website. However, certain features (like creating an account, purchasing services, or engaging with tutors) will require you to provide the information described above. If you choose not to provide necessary information, you may not be able to use some parts of the Services.

2. Information We Collect from Third Parties

We may obtain information about you from other sources in combination with information we collect directly. The categories of third-party sources include:

Schools, Educational Institutions or Organizations: If your access to our SAT prep Services is provided through your school, school district, tutoring franchise, or another organization (for example, if a school or program purchases accounts for its students, or a company offers our prep course to employees' children), we may receive personal information about you from that organization. This could include your name, contact information, student ID number, grade level, or other enrollment details so that we can create an account for you and provide the Services. We will use and protect that information consistent with this Privacy Policy (and any additional agreement with the providing organization). We may also share certain progress reports or performance information back with that organization as needed to fulfill our contract with them (see Data Sharing below).
Social Media or Third-Party Account Logins: Our Platform may allow you to register or log in via third-party authentication services (such as 'Sign in with Google' or similar). If you choose to connect or log in through a third-party platform, that service may send us certain information about you, such as your name, email, or public profile information, as permitted by their privacy policy and your account settings with that service. We will use any such information in accordance with this Privacy Policy. We also maintain pages on social networks like Facebook, Twitter, or Instagram. If you interact with our social media pages (for example, by messaging us or commenting on our content), we may collect information from your social media profile including your username and any other information you make public, and we will handle that information according to this Policy.
Marketing Partners and Lead Generators: We may receive your information from business partners or affiliates that help us market our Services. For instance, if you sign up on a third-party educational website to receive SAT prep information, or enter a co-sponsored contest or promotion, the information you provide (such as name, contact, interest in SAT prep) might be shared with us. We will treat such information in line with what you were told by the collector and this Privacy Policy.
Service Providers and Referral Sources: We could receive personal information about you from service providers that integrate with our Platform. For example, if we partner with an external test scoring service or an educational content provider to enhance our Platform, they might share results or data about you to incorporate into our Services (with appropriate consent if required). If a friend or family member refers you to our Services and you then sign up, we might associate that referral with your account.
Publicly Available Data: We may also supplement the information you provide with data obtained from public databases or publicly available social media profiles, but only as allowed by law. For example, for marketing or demographic analysis, we might collect public social media or web information indicating your interest in college or test prep. In general, any such supplemental data will be used for the purposes described in this Policy (like keeping our records accurate or better understanding our customer base).

3. Information Collected Automatically

Like many online services, we and our third-party partners automatically collect certain information about your device and usage of our Services through cookies, web beacons, and other tracking technologies when you visit our site or use our app. This automatically collected information includes:

Device and Usage Details: When you access our Platform, our systems and analytics providers log technical details about your visit. This includes your Internet Protocol (IP) address, device identifiers (such as advertising ID or unique device ID for mobile apps), browser type, device type (e.g., PC, tablet, mobile), operating system and version, language preference, screen resolution, and the date and time of your visit. We also record information about how you interact with our Services, such as the pages or content you view, the links or advertisements you click, referring/exit pages (i.e., the webpage that led you to our site and the page you go to when you leave), and the amount of time you spend on each page or feature.
Cookies and Similar Technologies: We use cookies, which are small text files placed on your browser or device, and similar tracking technologies like web beacons (small image files), pixels, tags, and local storage objects (e.g., HTML5 local storage). These technologies allow us to recognize you, remember your preferences, and understand how you use our Services. They help in various ways, such as keeping you logged in, saving your settings, analyzing traffic, or personalizing content. Some cookies are first-party cookies set by us, and others are third-party cookies set by analytics or advertising partners. For more details on cookies and your choices, see Cookies and Tracking Technologies below.
Analytics Information: We partner with third-party analytics providers (for example, Google Analytics, and others) to collect information about user activities on our Platform. These partners use cookies and similar tools to gather data about how you engage with our site (such as the pages you visit and the actions you take) and report website trends to us. This information helps us understand user behavior and improve our Services' functionality and user experience. It may include data such as your IP address, but analytics providers generally only report aggregate trends to us (e.g., total number of visitors, which pages are most popular, etc.) in a way that does not directly identify individual users.
Online Advertising Partners: We also work with advertising networks and marketing partners that use cookies and other tracking technologies to collect information about your browsing activities over time and across different websites or apps. These partners use the information to show you ads for our Services on other websites and to measure the effectiveness of our marketing campaigns. For example, if you visit our SAT course page, you may later see an advertisement for our Platform on a different site. The information collected through this process does not include your name, email, address or other directly identifiable information, but it may include identifiers like your device's cookie ID, IP address, or browser behavior. We provide more details about these practices in the Cookies and Tracking Technologies section, including how you can opt out of interest-based advertising.
Call and Chat Recordings: If you call our customer support line, we may record the call for quality assurance and training purposes. We will notify you at the start of the call if a recording is in progress. Similarly, if we offer live chat support, those chat conversations may be saved so we have a record of the support provided. These recordings and transcripts will be used only internally to improve our customer service and resolve any issues you raise.
Location Information: We do not typically collect precise geolocation (e.g., GPS coordinates) unless you specifically permit it via your device settings. However, we can often infer an approximate location (such as city or state) from your IP address or billing information. We use this approximate location to customize our Services (for example, displaying times in your time zone or showing relevant class offerings for your region) and to comply with local legal requirements (like displaying the correct privacy notices).

Combination of Data: We may combine information collected from you through various means (e.g., information you provide and information collected automatically) and from third-party sources. For example, the insights from usage data and the contact info you provided might be used together to recommend a study plan tailored to your needs. We treat all combined data as personal information under this Privacy Policy.

How We Use Your Information

We use the personal information we collect for a variety of business and operational purposes. Our primary goal is to provide you with a safe, efficient, and personalized SAT learning experience. Below are the purposes for which we use your information:

Providing and Improving Services: We use your information to provide our tutoring and test preparation services to you. This includes using your data to create and manage your user account, enroll you in courses or tutoring sessions, deliver lesson content and practice questions, and track your progress. We also use data (like feedback and usage data) to continually improve the curriculum, platform interface, and performance of our Services. For example, understanding which practice quizzes are most challenging for users can help us refine our materials.
Personalizing Your Experience: Personal information allows us to customize the learning experience to your needs. We might use your grade level, prior test scores, or indicated target score to suggest appropriate lesson plans or practice tests. We may tailor the content you see -- such as recommending certain study resources or adjusting difficulty level -- based on your performance and preferences. Personalization also applies to communications: for instance, if we know you're registered for an upcoming SAT exam, we may send you timely study tips or reminders.
Processing Transactions: We use financial and contact information to process payments for our Services you purchase, and to deliver confirmations, receipts, or other transactional messages. For example, if you sign up for a tutoring package, we will charge your credit card and send you a payment receipt by email. If you are a tutor or contractor, we will use your information to process payroll or stipend payments to you. We maintain internal records of transactions for accounting, audits, and dispute resolution.
Communicating with You: We use your contact information to communicate with you about your account or the Services. This includes sending service-related announcements and administrative messages. For example, we may send email/SMS notifications to confirm your registration, remind you of an upcoming tutoring session or test date, provide updates about curriculum changes, or alert you to customer service issues or policy updates. These communications are typically necessary to perform our contract with you or to inform you of important information about the Services. If you contact us with a question or support issue, we will use your provided information to respond to and resolve your inquiry.
Marketing and Promotional Correspondence: We may also use your information to send you newsletters, offers, and other marketing communications about our products, services, new features, or events that may be of interest to you. For example, we might email you about a new SAT prep workshop, discounts on tutoring bundles, or related educational services we offer. You have control over marketing messages -- see Your Rights and Choices below for how to opt out of promotional communications. If an organization (like your school) arranged for your use of the Platform, we may limit marketing communications or tailor them according to our agreement with that organization (for instance, focusing only on relevant academic programs).
Collecting Feedback and Testimonials: We may ask you to provide reviews, testimonials, or to answer survey questions about our Services. If you choose to give feedback or testimonials, we may use your responses to improve our offerings or publish your testimonial (with your consent) on our website or marketing materials. For example, if you provide a success story about your SAT score improvement, we might display it on our site -- but we will either anonymize your identity or obtain permission to use your name. Participation in surveys or providing testimonials is completely voluntary.
Facilitating Referrals and Promotions: If you use a refer-a-friend program, we use your and your friend's information to send the referral invitation as described above, and to credit you with any referral benefit. If we run sweepstakes, contests, or similar promotions, we use the information you provide to administer the promotion (e.g., to contact winners, deliver prizes, and as required by law, list winners). We will provide additional terms for any promotions, which may describe additional uses of your information.
Advertising and Personalization on Other Platforms: We may use information about you to serve you targeted advertisements on third-party platforms and websites. For example, using cookies and identifiers (as described in Cookies and Tracking Technologies), we might work with advertising networks (like Google or Facebook) to display ads for our Services that are more relevant to you. If you have already used our Services, we might show you ads for advanced programs; if you've visited our site but not signed up, we might show you an ad offering a free trial to encourage you to join. We also analyze the results of our advertisements (e.g., seeing if people who saw an ad later signed up) to gauge effectiveness. Note that we do not share information that directly identifies you (like your name or email) for advertising purposes without your consent; we typically use hashed or device-level data for matching. See Cookies and Tracking Technologies for more on advertising and your choices.
Analytics, Research, and Product Development: We analyze usage information, test results, and feedback to understand trends and user preferences. This helps us to troubleshoot performance issues, conduct research on study outcomes, and develop new products or features. For instance, analyzing which types of questions students get wrong can guide us in creating new practice materials or clarifying our instructional content. We may also use aggregated or de-identified data (which cannot personally identify you) for academic research purposes or to share insights about SAT preparation trends.
Security and Fraud Prevention: Your information is used to maintain the safety and integrity of our Platform. We monitor activity to detect and prevent fraudulent transactions, cheating or misuse during tests or tutoring sessions, network and information security breaches, and other malicious or illegal activity. For example, we may use certain data to verify account login attempts or flag suspicious behavior on an account. If necessary, we'll use and share information required to investigate and mitigate fraud, security vulnerabilities, or violations of our Terms of Use or law (see Data Sharing below in cases of potential harm or legal requirements).
Legal Compliance and Enforcement of Rights: We may use your information to comply with applicable legal obligations, such as fulfilling lawful requests by public authorities, responding to subpoenas or court orders, or meeting reporting and audit requirements. Additionally, we will use and potentially disclose data as necessary to enforce our Terms of Use or other agreements and to protect the rights and safety of our organization, our users, or others. For example, we may retain and use records of certain communications or behaviors to investigate a violation of our academic honesty policies or to handle a consumer rights request under law.
Other Purposes with Notice or Consent: We may use your information for any other purpose that we describe at the time we collect it, or otherwise with your additional consent. If we want to use your data in a way not covered by this Privacy Policy, we will let you know at the point of collection or contact you later to explain the new use and obtain consent when required. You have the choice not to participate in such new uses.

We may also use non-personal information (information that does not identify you as an individual, such as aggregated data or de-identified data) for any purpose, as this information cannot be used to identify you. For instance, we might publish aggregate statistics like 'Students who took at least 5 practice tests improved their scores by an average of X points' without revealing any personal details.

Cookies and Tracking Technologies

Our Platform uses cookies and similar tracking technologies to ensure our website functions properly, to understand and improve your experience, and to deliver relevant content and advertising. This section explains how we use these technologies and your choices related to them.

What Are Cookies?
Cookies are small text files placed on your computer or device when you visit a website. They allow the website to recognize your device and store certain information about your preferences or past actions. Other technologies that serve similar functions include web beacons (also known as pixel tags or clear GIFs, which are tiny images embedded in a webpage or email that track if you have viewed the content), scripts, and local storage objects (like HTML5 local storage and Flash cookies) that can store information in your browser. For simplicity, we refer to all these technologies as 'cookies.'

How We Use Cookies:
We and our third-party service providers use cookies for several reasons, such as:

Essential Cookies: These are necessary for our site to function. For example, they enable you to stay logged in as you navigate between pages, keep track of items in your shopping cart, or ensure that content loads quickly and correctly. Without these cookies, certain services or features cannot be provided, and our site may not perform as smoothly for you.
Functional Cookies: These cookies remember your preferences and settings to enhance your experience. For instance, they may recall your username (so you don't have to re-enter it each time you log in), your chosen language or region, or other customizations you've made on the Platform. They can also remember past tutoring sessions or pages you've visited to help you pick up where you left off.
Analytics Cookies: We use analytics cookies to collect information about how visitors use our site. This includes which pages are visited most often, how users navigate the site, what times of day have the most traffic, and whether users encounter error messages on certain pages. The information these cookies provide is aggregated and not directly identifiable to you. For example, we might use Google Analytics cookies to see that '50 users visited the Math practice page today and spent an average of 5 minutes.' This data helps us identify areas to improve -- such as reorganizing a popular page for easier use or fixing pages where errors occur.
Advertising and Marketing Cookies: These cookies are used to deliver advertisements relevant to you and to measure the effectiveness of our marketing campaigns. Third-party advertising partners may set these cookies through our site. They remember that you've visited our Platform or engaged with certain content, and they may track your browsing across other sites. For example, if you visited our site and then later browse another website, these cookies can enable the display of an ad for our SAT course on that site. Advertising cookies may also limit the number of times you see the same ad and measure whether an ad was viewed or clicked. We also use cookies in our emails to measure engagement -- for example, to track if you open an email or click on a link inside it, which helps us refine our communications.

Third-Party Cookies and Tracking:
We work with certain third parties that deploy their cookies or other tracking technologies on our Platform to assist us with various functions:

Analytics Providers: As mentioned, we use tools like Google Analytics (and possibly others, such as Facebook Analytics or Mixpanel) to understand site usage. Google Analytics may set cookies or use device identifiers to collect usage data. Google provides an option for users to opt-out of Google Analytics tracking; you can install the Google Analytics Opt-out Browser Add-on for your browser if you do not want your data to be used by Google Analytics. Similarly, if we use other analytics tools, they may have their own opt-out mechanisms or privacy policies explaining how they collect and use data (for example, Facebook's analytics or advertising tools are subject to Facebook's Data Policy).
Advertising Partners: We may partner with advertising networks like Google Ads, Facebook Ads, Bing Ads (Microsoft), or LinkedIn, among others. These partners use cookies and pixels to collect information about your activities on our site and other sites to provide you with targeted ads. For example, the Google Ads network may use a cookie to note that you visited our site, and then use that information to show you an ad for our services on a Google search results page or on a site in Google's advertising network. Similarly, Facebook might use a pixel on our site to later show you an ad in your Facebook or Instagram feed. These advertising partners may also use information about your past online activities to tailor ads on our site -- for instance, if you have shown interest in college admissions content elsewhere, you might see ads on our Platform related to college application help.
Social Media Features: Our site might include features that allow you to share content or connect your account with third-party social media platforms (like a Facebook 'Like' button, a Twitter 'Tweet' button, or other widgets). These features may set cookies or collect your IP address and which page you are visiting on our site, in order to function. They might also identify you as logged into your social media account (such as if you are logged in to Facebook in your browser, the Facebook 'Like' button can associate your action with your profile). Social media features and widgets are either hosted directly on our site or by the third-party platform. Your interactions with these features are governed by the privacy policy of the company providing them (e.g., Facebook's Data Policy, Twitter's Privacy Policy).

Your Choices for Cookies:
You have several options to control or limit how cookies and similar technologies are used on your device:

Browser Settings: Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or alert you when a cookie is being placed on your computer. Check your browser's help or support menu for instructions on how to adjust your cookie settings. For instance, you can typically find options under the browser's 'Settings' or 'Preferences' section to manage cookies. You may be able to remove or reject cookies, including cookies used for interest-based advertising. Please note: If you disable or delete certain cookies, it may affect the functionality of our site. Essential parts of the Platform might not work properly because, for example, you might not be able to stay logged in or some preferences (like language or region) might not be saved.
Third-Party Opt-Out Options: For third-party advertising cookies, you can visit industry opt-out pages to set preferences and opt out of interest-based advertising. Here are a few resources:
- The Network Advertising Initiative (NAI) opt-out page: http://optout.networkadvertising.org -- allows you to opt out of many ad networks' targeted advertising.
- The Digital Advertising Alliance (DAA) opt-out page: http://optout.aboutads.info -- another option for opting out of targeted ads from participating companies in the United States.
- For users in the EU/EEA, the European Interactive Digital Advertising Alliance (EDAA) offers an opt-out page: http://www.youronlinechoices.com.
- Google Ads: You can manage your Google ad settings and opt-out of personalized ads through Google's Ads Settings (https://adssettings.google.com) if you have a Google account.
- Facebook Ads: To adjust your ad preferences on Facebook, you can use the settings in your Facebook account (look for Ad Preferences in your Facebook settings).

Using these opt-out mechanisms typically places an opt-out cookie on your browser, so if you clear cookies, use a different browser/device, or later reinstall your browser, you may need to opt out again.

Do Not Track Signals: 'Do Not Track' (DNT) is a privacy preference that users can set in some web browsers to signal that they do not wish to be tracked across different sites. Currently, there is no consistent standard or regulation for how websites should respond to DNT signals. As a result, our Platform does not respond to Do Not Track signals at this time. We treat all visitors equally, whether or not a DNT signal is received. We will update this practice if an industry standard for online tracking is established in the future.
Mobile Settings: If you are using our mobile app, your device operating system (iOS, Android, etc.) may offer options to opt out of certain types of tracking, such as resetting your device's advertising identifier or limiting ad tracking. Check your device's privacy settings for such options. Additionally, to disable location tracking via the app, you can adjust the app's permissions in your device settings to prevent access to location data.

Local Storage Objects: In addition to cookies, we may use local storage (like in-browser HTML5 or application data caches) to store content information and preferences. Browsers may offer their own management tools for removing HTML5 local storage (for example, clearing your cache or site data in the browser settings). If our Platform uses Flash cookies (Adobe Flash local shared objects) for any reason (some video content players do), note that Flash cookies are managed through a different interface than the one provided by your web browser. Visit the Adobe website for information on how to control Flash cookies. However, as our focus is on SAT prep content, we primarily rely on standard cookies and do not foresee heavy use of Flash cookies.

Note: Even if you opt out of targeted advertising, you will still see advertisements online, but they may be less relevant to you because they won't be tailored based on your interests and past browsing. Also, opting out via the above mechanisms is generally cookie-based, so if you clear your cookies, the opt-out may no longer be in effect.

How We Share Your Information

We understand that your personal information is important, and we are not in the business of selling your data to third parties for their independent marketing purposes. However, in the normal course of running our business, we do share information with others under certain circumstances. This section explains when and with whom we may share your information. We share personal information only as described below, and when we do, we require recipients to protect the information and use it only for the purposes described.

1. Service Providers (Processors)

We employ and contract with trusted third-party companies, service providers, and individuals to help us operate our Platform and deliver our Services on our behalf. Examples include:

Payment processing companies (to securely handle credit card transactions or tutor payouts)
Cloud hosting providers and database/storage providers (to host our website, applications, and data)
Email delivery services and SMS gateway providers (to send service emails, notifications, or text messages)
Analytics and performance monitoring tools (to help us analyze usage and improve our service)
Marketing and advertising partners (to manage and execute marketing campaigns or show ads, as described above)
Customer support tools and customer relationship management software (to manage communications with you)
Webinar or video conferencing platforms (if we use them to host live online classes or tutoring sessions)
Background check services (for vetting tutors or staff, with appropriate safeguards)

These third-party service providers may access or process your personal information as needed to perform tasks on our behalf. However, we authorize them to use or disclose the information only as necessary to provide services to us (for example, only to process payments, or only to send emails on our behalf, etc.) and not for their own marketing or other purposes. We have contracts in place with our service providers that require them to protect the confidentiality and security of personal information they process for us and to comply with applicable privacy laws.

2. Within Our Corporate Family (Affiliates)

If our company has any parent company, subsidiaries, joint ventures, or other companies under common control (collectively, 'affiliates'), we may share your information with these affiliated entities, who are bound by privacy commitments similar to ours. For example, if our SAT prep platform is part of a larger education group or is owned by a parent company that operates other educational services, we might share resources or infrastructure. We may share your data with our affiliates for purposes consistent with this Privacy Policy, such as internal administration, customer support, or to offer you related services (if permitted by law). If, in the future, one of our affiliates offers a complementary educational service, we might share your contact information with them so they can reach out to you, but only if such sharing is allowed and with appropriate opt-out or consent mechanisms in place as required by law.

3. Business Partners and Integrations

In some cases, we may partner with other businesses or organizations to offer co-branded services, integrate features, or sponsor events. If you engage with such partnership features, certain information may be shared with the partner:

Organizational Partnerships (Schools/Employers): If your participation in our Services is arranged or financed by a third party -- for example, your school, a school district, a library, a nonprofit, or your or your parent's employer -- we may share with that organization information about your use of our Services. This could include enrollment status, attendance, progress reports, quiz/exam results, or tutoring session records. We only share what is needed and expected as part of providing the service to you under that organization's sponsorship. For instance, a high school that signs up its juniors for an SAT bootcamp may receive aggregate reports on student progress or even individual performance data if agreed. We abide by any contractual obligations with such organizations regarding data handling, and we comply with laws like the Family Educational Rights and Privacy Act (FERPA) when applicable (e.g., if we handle education records on behalf of a school).
Tutor Matching: If you are a student, certain information about you will be shared with the tutor(s) or instructors that work with you so they can provide effective instruction. This includes relevant details like your first name, general location (to align time zones or if in-person components exist), academic history or areas of concern (e.g., 'struggles with algebra' or your practice test results), and any specific goals or accommodations you require. Similarly, if you are a tutor on our Platform, students may see some information from your public tutor profile such as your first name, biography, qualifications, and reviews from other students. We do not disclose students' full contact information to tutors (or vice versa) through the Platform without consent or unless necessary for the service (for example, if a specific program requires a tutor to send materials by mail, we would do so with permission). Communications between students and tutors on the Platform (via chat or messaging features) are generally private to those participants and our system administrators.
Third-Party Product Resellers or Integrations: In some cases, we might offer third-party products or services through our Platform (for example, if we resell an SAT practice book from a partner publisher or integrate an admissions counseling service). If you purchase or express interest in a third-party product offered through our Platform, we may share your relevant details with the provider of that product so they can fulfill the purchase or follow up with you. For example, if we resell a college application review service and you sign up for it, we would provide your contact info and any necessary educational details to that partner to initiate the service. Those third parties will use your information in accordance with their own privacy policies, which we will identify to you at the time (and we recommend you review any such policy). We will only share with such partners what is necessary for the transaction or service (and with your consent where required).
Events and Co-Sponsored Programs: If you register for an event or webinar that we offer in conjunction with a partner (like a college fair or a scholarship contest), and you provide information as part of that event registration, we may share your registration details with the partner co-sponsoring the event. They will use that information for organization of the event or as otherwise disclosed on the event terms (for example, to send you event materials or follow up surveys). We will let you know at sign-up if a partner will receive your information, and if they may use it for additional purposes (with your consent, if required).

We do not sell or rent your personal information to third parties for their independent use. We also do not share your personal data with unrelated third parties for their direct marketing unless you have requested or consented to such sharing (for instance, if you explicitly request information from a university through our Platform, we may forward your details to that university).

4. Legal Compliance and Protection

We may disclose your personal information when we believe in good faith that such disclosure is necessary to:

Comply with the Law: We will share information if required to do so by applicable law, regulation, legal process, or governmental request. This includes responding to lawful subpoenas, court orders, warrants, or requests from authorities or regulators. For example, if a law enforcement agency properly requests data regarding users engaged in suspected unlawful activities, we may be obligated to provide it.
Protect Rights, Safety, and Property: We may disclose information if we believe it is appropriate to enforce our Terms of Use or other agreements, or to investigate potential violations thereof. We will also share data as needed to detect, prevent, or address fraud, security, or technical issues. If a user is suspected of cheating on a test, engaging in harassing or dangerous behavior on the Platform, or threatening the safety of someone, we may share relevant information with appropriate parties (such as the affected school, law enforcement, or our legal counsel) to address the situation. Additionally, we may release information to protect our rights and property, as well as the rights, property, and safety of our users or others. This could include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

In summary, any legally compelled disclosure or disclosure made for safety reasons will be narrowly tailored to the information required or pertinent to the issue at hand.

5. Business Transfers

As we continue to develop our business, we might sell, merge, or reorganize our company or assets. In the event of a business transaction such as a merger, acquisition by another company, reorganization, sale of all or a portion of our assets, financing, or as part of bankruptcy or receivership, your personal information may be transferred to the acquiring or successor entity as part of the transaction. For example, if our Platform or company is acquired by another educational company, customer information (including personal data) would likely be one of the assets transferred. In such cases, we will ensure that the successor entity is bound to the same commitments stated in this Privacy Policy with respect to your personal information (unless and until you are notified of changes via an updated Privacy Policy and given any applicable choices). We will also endeavor to notify you (for example, via email or a prominent notice on our site) of any such change in ownership or control of your personal information, if and as required by law.

6. With Your Consent or At Your Direction

Beyond the situations above, we will share personal information with companies, organizations, or individuals outside of our organization when we have your consent or when you explicitly direct us to do so. For example:

If you request that we share your score results or course progress with a specific third party (like a tutor, counselor, or parent not already on our system), we will do so with appropriate verification and consent.
If you choose to participate in an external research study or survey that involves us sharing your data, we will do so only with your knowledge and permission.
If you make parts of your profile publicly visible (such as posting a question on a public forum or participating in a discussion board), you are effectively consenting to the information being seen by anyone, including information that identifies you as the author of the content. (We strongly advise caution when sharing personal details in any public areas of our Services---see Public Forums below.)

In any case where additional consent is required by law for sharing, we will obtain such consent before sharing your personal data.

7. Sharing of Aggregated/De-Identified Data

We may share information that has been aggregated (combined with information of other users) and/or de-identified (stripped of personal identifiers like name or email, so that you are not readily identifiable). Such information is not considered personal information and may be shared freely. For example, we might publish a report that states '95% of our students saw score improvements' or share user statistics with educators or researchers. This data will not identify any individual and is used to promote or analyze our services and contribute to educational research.

Your Rights and Choices

We believe it's important that you are able to control your personal information. Depending on your location and the nature of your relationship with us, you have certain rights and choices regarding how your information is used and disclosed. This section describes the tools and mechanisms available to you for managing your privacy.

1. Accessing and Updating Your Account Information

If you have an account on our Platform, you can access, correct, or update much of your basic personal information directly through your account profile page. For example, you can log in and update your contact information (email, phone, address), change your password, or modify other profile details at any time. We encourage you to keep your information up-to-date.

If any personal information we have about you is inaccurate or needs to be updated and you are unable to change it yourself, you may contact us (see Contact Us below) to request modification. We will take reasonable steps to verify your identity before making corrections, and we will update our records promptly. In certain cases, we may retain historical information in our records (for example, old addresses or email addresses) as required by law or for legitimate business purposes (like keeping a record of communications or transactions), but we will not use outdated information for active business purposes.

2. Email and Communication Preferences

Promotional Emails: If you previously agreed to receive promotional communications from us (such as newsletters, special offers, or other marketing emails), you can opt out at any time. To unsubscribe, simply click the 'unsubscribe' or 'opt-out' link in any marketing email you receive from us. You can also manage your email preferences by logging into your account (if you have one) and adjusting the settings under your communications or notification preferences. Alternatively, you may contact us at the email address provided in Contact Us and specify which communications you want to opt out of. For example, you can state that you want to opt out of 'all marketing emails' or only certain types (like 'newsletter' or 'event invitations'). Please note that even if you opt out of promotional emails, we may still send you transactional or service-related emails as needed. These include messages like confirmations of transactions, updates about your courses or account, password reset emails, or policy updates. You cannot opt out of these essential communications because they are necessary for us to provide our services to you.
Text Messages (SMS) and Calls: If you have provided your phone number and consented to receive SMS/text messages or automated calls (for example, reminders for sessions or marketing alerts), you have the right to opt out. You can opt out of text messages at any time by replying 'STOP' (or as instructed in the message) to any text you receive from us. After you text STOP, we may send you a confirmation message and then stop texting you (aside from urgent or individually composed messages from a human agent, if any, which we would limit). For opting out of promotional phone calls, you can request to be placed on our internal 'Do Not Call' list by contacting us via email or phone. If you receive a call from us, you can also let the caller know you do not wish to receive further marketing calls. Please note, if you are involved in ongoing services (like scheduled tutoring sessions), we may still call or text you regarding those services (e.g., a tutor trying to reach you, or an appointment reminder) even if you opt out of general marketing communications, as these may be considered operational communications. Standard message and data rates may apply for any texts we send; if you opt out, you will no longer receive texts but any future needed communications will be sent by email or phone call.

3. Cookie Preferences and Advertising Opt-Out

As detailed in Cookies and Tracking Technologies, you have options to control the use of cookies and tracking tools on our site. You can set your web browser to refuse some or all cookies, and you can use industry opt-out sites to limit interest-based advertising. If our site has a cookie consent banner or settings (for example, some sites allow you to toggle which categories of cookies you accept), you can use that tool upon your first visit or anytime via a 'Cookie Settings' link in the footer (if available). Keep in mind that essential cookies are needed for the site to function. For advertising, you can opt out of third-party ad networks as described above. Even after opting out, you might still see our ads in a generic context (not targeted specifically to you).

If you use multiple devices or browsers to access our Services, you will need to set your cookie preferences on each device/browser. Also, because cookie-based opt-outs (like the DAA or NAI choices) depend on cookies, if you clear your cookies you may need to opt out again.

4. 'Do Not Sell or Share My Personal Information' (for California Residents)

We do not sell personal information for monetary consideration. We also do not 'share' personal information for cross-context behavioral advertising in a way that is governed by California law (see more in State Privacy Rights below). If you are a California resident and still wish to formally opt out of any potential 'sale' or 'sharing' of your data, you can contact us to record your preference (see State Privacy Rights for how to submit requests). We will honor and record such opt-out requests. Additionally, if our Platform in the future enables advertising cookies that might be considered a 'sale' or 'share' under California law, we will provide a 'Do Not Sell or Share My Personal Information' link or toggle on the site as required.

5. Account Deletion and Data Erasure

You have the right to request deletion of your personal information in certain circumstances. You may request that we delete your account and the personal data associated with it by contacting us (see Contact Us). Upon receiving a verified deletion request, we will delete or anonymize your personal information from our records, except for information we are required or permitted to retain by law or for legitimate business purposes. For example, we might need to keep certain data for recordkeeping, to comply with financial or legal obligations (such as tax records or proof of consent), to resolve disputes, or to enforce our agreements. We will inform you of the scope of data we can delete and any data we must retain. Also note that due to backups and archives, residual copies of your information might take a brief period to be fully removed from all systems, but we will cease active use of the data immediately after processing your request.

If you simply wish to discontinue using the Platform, you might also have the option to deactivate your account through your account settings. Deactivation stops further processing of your data for routine use, but full deletion would require a request as described above.

6. Other Rights Under Applicable Law

Depending on where you live, you may have additional legal rights over your personal information. For example, residents of certain states (such as California, Virginia, Colorado, Connecticut, and Utah) have specific rights under state laws. These can include:

Right to Know/Access: The right to request details about the personal information we have collected about you, including the categories of information, the sources of that information, the purposes for the collection, and the categories of third parties with whom we have shared or disclosed it. You also have the right to request a copy of the specific pieces of personal information we have about you (provided in a portable and, if feasible, readily usable format).
Right to Correction: The right to request that we correct inaccuracies in your personal information, taking into account the nature of the information and the purposes of processing.
Right to Delete: The right to request deletion of personal information we have collected from you, subject to certain exceptions (as discussed above).
Right to Opt-Out of Sale/Sharing or Certain Processing: If we engaged in practices considered a 'sale' of personal data or 'sharing' for targeted advertising, you would have the right to opt out of that. Additionally, some laws provide the right to opt out of the use of personal data for profiling in furtherance of decisions that produce legal or similarly significant effects. (At this time, we do not engage in such profiling or selling of personal data as defined by those laws, other than standard advertising cookies which you can opt out of as described.)
Right to Non-Discrimination/No Retaliation: We will not discriminate against you or retaliate in any way if you choose to exercise any of your privacy rights. That means we won't deny you services, charge you different prices, or provide you a lesser experience because you made a privacy rights request. However, in some cases, if you ask us to delete data or restrict processing, and that data is necessary for the provision of the Service, we may not be able to continue providing certain services to you (for example, if you ask us to delete all of your account data, we cannot provide tutoring services to you). We will inform you if such a situation arises.
Right to Appeal: If we decline to take action on a request you make (for example, if we had to deny a deletion request because an exemption applied), certain laws (like Virginia's CDPA) allow you to appeal our decision. We would provide you with information on how to appeal in our response to any such request denial.

To exercise any of these rights, please see the next section on State Privacy Rights for instructions specific to certain jurisdictions. For rights not explicitly covered there or general inquiries, you can always reach out to us via the contact methods in Contact Us. We will need to verify your identity before fulfilling certain requests (to ensure that we don't give your data to someone else), and we will respond within the timeframe required by law. Verification might involve confirming information we already have on file (such as you confirming a code sent to your email or verifying past transaction details).

Keep in mind that your rights are subject to certain limitations. For example, if fulfilling your request would reveal personal information about another individual, we may need to redact or refuse that portion of the request. If you have authorized an agent to make a rights request on your behalf, we will take steps to verify the agent's authority and your identity, typically by requiring a signed authorization and direct confirmation from you.

State Privacy Rights

Privacy laws in certain U.S. states provide residents of those states with specific rights regarding their personal information. In this section, we provide additional information for residents of California (under the California Consumer Privacy Act as amended by the California Privacy Rights Act, collectively 'California Privacy Law') and other states with similar laws like Virginia (Virginia Consumer Data Protection Act, 'VCDPA'), Colorado (Colorado Privacy Act), Connecticut (Connecticut Data Privacy Act), and Utah (Utah Consumer Privacy Act). We also include information for Nevada residents under Nevada law. This section is intended to supplement the rest of our Privacy Policy and to ensure compliance with these state-specific requirements.

If you are a resident of one of these states, you may exercise the following rights regarding your personal information, as applicable and subject to any exemptions or limitations provided by law:

1. Categories of Personal Information We Collect (California-specific disclosure):
California law requires us to tell California consumers about the categories of personal information we collect and how we use and disclose it, as defined by the law. Throughout this Privacy Policy, we describe the specific pieces of information we collect and their purposes. For ease of reference, the categories of personal information (as defined by California law) that we have collected in the past 12 months include:

Identifiers: Such as real name, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account username, or other similar identifiers. (We collect these directly from you when you register or use our Services, and from your device via cookies/analytics.)
Customer Records Information: This includes personal information described in the California Civil Code § 1798.80(e), such as payment information (some of which overlaps with Identifiers), billing and shipping address, and payment card details. (We collect these when you make purchases or provide them for transactions.)
Protected Classifications: Characteristics of protected classifications under California or federal law, such as age (since we may collect date of birth or age range, for instance to ensure COPPA compliance or tailor content), gender (if you choose to provide it or it's inferred from your salutation), or possibly information like ethnicity or disability status if you voluntarily provide it for accommodation purposes. We do not actively collect sensitive protected class info unless a user provides it (e.g., indicating a disability that requires accommodation in learning, or if a tutoring program is aimed at a specific community). Any such information is used strictly to provide services or as required by law (e.g., reporting demographic data in aggregate for scholarship programs).
Commercial Information: This includes records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. (For example, which courses you enrolled in, which tutoring packages you bought, and your history of inquiries or service usage.)
Internet or Other Electronic Network Activity: This includes browsing history, search history, and information regarding your interaction with our website, app, or advertisements. (We collect this via cookies and similar technologies as described, including things like pages viewed, links clicked, time stamps, and IP-based location data.)
Geolocation Data: We do not collect precise GPS geolocation without consent, but we may collect general location data (such as city, state, or country) inferred from IP address or you might provide an address for billing or as part of your account profile. This is non-precise location data used for things like regional content or legal compliance (e.g., showing correct privacy disclosures by state).
Audio, Electronic, Visual, or Similar Information: Such as call recordings (audio) when you contact customer support, or video recordings if you participate in a recorded tutoring session or if you voluntarily submit a video testimonial. Also, photographs you may upload (for instance, a profile picture or images in assignments) would fall into this category. We only record or collect these with notice to you (e.g., notifying you a call is recorded, or a tutoring session is being recorded) or by your direct submission.
Professional or Employment-related Information: If you are a tutor or job applicant, we collect professional info like your employment history, qualifications, education, and for tutors, perhaps your current employer or school affiliation if relevant. For students, we may collect limited school-related info (like your high school name, graduation year, GPA, etc., which might be considered educational rather than professional info). We do not collect employer information for students unless the employer is sponsoring the program.
Education Information (Protected under FERPA): As an educational service provider, we may handle education records on behalf of schools or directly from students/parents. This can include test scores, transcripts, grades, or other academic information. If we receive such information from a school or directly from a student for tutoring purposes, we treat it in compliance with FERPA as applicable (meaning we use it only for educational purposes for the student and do not disclose it except as permitted by the student/parent or school). We consider this part of personal information as well.
Inferences: Inferences drawn from other personal information to create a profile about a consumer reflecting their preferences, characteristics, psychological trends, predispositions, behavior, intelligence, abilities, or aptitudes. For example, we might infer that you are likely to take the SAT based on your grade level, or infer your preferred learning style based on your engagement patterns. We primarily use such inferences to personalize your experience (e.g., suggesting certain study materials if we infer you need more practice in math vs. verbal).

We collect these categories of information from the sources and for the purposes described in Information We Collect and How We Use Your Information. The categories of third parties to whom we disclose these categories of information are described in How We Share Your Information and may include service providers, affiliates, business partners, and others as detailed.

As a newly established business, we currently have no prior disclosures or sales of personal information to report under California law.

2. Rights of California, Virginia, and Other State Residents:
If you are a resident of California, you have the rights listed in the Your Rights and Choices section (the right to know/access, delete, correct, opt-out of sale/sharing, limit use of sensitive info (if we collected any such info for reasons other than permissible ones), and not be discriminated against for exercising rights). Residents of Virginia, Colorado, Connecticut, and Utah have similar rights (access, correct, delete, opt-out of targeted advertising/sale/profiling). We will respond to verifiable consumer requests to exercise these rights in accordance with state law requirements.

How to Submit a Request: To exercise any applicable rights, you (or an authorized agent acting on your behalf) may contact us through any of the methods described in Contact Us (for example, by email or mail). Please indicate that you are making a 'privacy rights request' and specify your state of residence and which right you seek to exercise (e.g., 'California Access Request' or 'Virginia Deletion Request'). For certain requests, we may provide a specific web form to capture the necessary information. If a specialized request form or portal is available (we may implement an online Privacy Center or specific URL for state law requests), we will direct you to it for convenience, but using email or mail is always an option.
Verification Process: When you make a request, we need to verify your identity to ensure we are dealing with the actual person (or their authorized agent) whose data is involved. The verification steps may vary depending on the request's sensitivity. Typically, we will ask you to provide at least two or three pieces of information that we can match against our records (for example, your full name, the email address associated with your account, your last transaction amount or date, or other details we have on file). For deletion or access to specific pieces of information, which are more sensitive requests, we may require a higher level of verification, such as a signed declaration under penalty of perjury that you are the consumer whose data is the subject of the request. If you have an account with us, we may verify by requiring you to sign in to that account or respond to communications sent through the account (though we will never ask for your password or login credentials directly). If you use an authorized agent to submit a request on your behalf, we will require:
- Proof of the agent's authorization to act on your behalf. This could be a notarized letter signed by you, a valid power of attorney, or other written authorization.
- We may also require you to directly confirm with us that you provided the agent permission (to avoid fraud).
- The agent will also need to verify their own identity to a reasonable certainty.
Response Timing: We will confirm receipt of your request within 10 days (for California) and provide information on how we will process it. We will respond to consumer requests within 45 days of receipt (for California and similarly under other state laws). If we need more time (up to an additional 45 days, for a total of 90 days), we will inform you of the reason and extension in writing. Our response will be delivered either through your account (secure inbox) or via email or postal mail, depending on how you submitted the request and what method you prefer or is appropriate.
Response Content: For access requests, we will provide the requested information covering the 12-month period preceding our receipt of your verifiable request (or longer, if required by certain new laws like CPRA for some information). If you request specific pieces of information, we will provide them to you (after verifying to a high degree of certainty). For deletion requests, we will confirm deletion or de-identification (or explain the basis for denial if we must deny it). For correction, we will inform you that we corrected it or that we have no records that need correction if they were already accurate (or explain if we cannot comply, e.g., if we believe the contested data is more likely correct). For opt-out requests (sale/sharing), we will confirm that we have processed your opt-out and will not sell/share your data unless you later opt back in. If we deny any part of a request, we will explain the reason (for example, we cannot delete data that is required to complete a transaction you requested, or we could not verify your identity with sufficient confidence, etc.). In case of a denial in a state that grants a right to appeal (like Virginia), we will also explain how you can appeal our decision. Appeals will be reviewed by a different personnel member than the one who made the initial decision, and we will respond to an appeal within the timeframe the law specifies (e.g., 60 days in Virginia). If the appeal is denied, we will provide any further recourse as required (e.g., contact information for your state's Attorney General if applicable).

3. Sensitive Personal Information (California):
California's CPRA defines certain data as 'sensitive personal information' (SPI), which includes things like Social Security Numbers, financial account login info, precise geolocation, race/ethnic origin, contents of mail/messages, etc. We do not collect most types of SPI from consumers, except:

Account login combined with password (for your account on our Platform) could be considered SPI. However, we use this only to provide you access to your account, and we do not use or disclose it for purposes beyond the permissible ones (like providing the service or preventing fraud).
If you voluntarily provide sensitive info such as a health-related need (e.g., you tell us about a learning disability to accommodate) or demographic info (race/ethnicity) for a program, we treat that as highly confidential and use it only for the purpose for which you provided it (for instance, to accommodate your learning or to report anonymized demographic participation data).

Under CPRA, consumers have the right to limit the use of SPI if it's used for purposes beyond what's necessary to provide the services. We do not use or disclose sensitive information for any purpose that would trigger a 'Right to Limit' under CPRA -- we only use such information to provide you services or as otherwise permitted (e.g., security, short-term transient use, etc.). Therefore, we don't offer a specific 'Limit Use of Sensitive Information' mechanism, as it's not applicable to our data practices at this time.

4. California 'Shine the Light' Law:
California Civil Code Section 1798.83 (the 'Shine the Light' law) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their independent direct marketing purposes without consent. That means, unless you separately consent (e.g., by requesting info from a partner or opting in to a mailing list of a partner via our Platform), we won't disclose your data to other companies for them to market their products to you. If you still wish to learn about any such activity, you can send us a request as described in Contact Us. Typically, because we don't engage in that type of sharing, our response will confirm that and thus satisfy the inquiry.

5. Nevada Residents:
Nevada law (NRS 603A) allows Nevada consumers to opt out of a 'sale' of certain personal information to third parties for licensing or sale purposes. We do not currently sell personal information as defined under Nevada law. If we ever change this practice, Nevada residents will be provided with an opportunity to opt out. Nevada residents may still send us a verified request to opt out of sales under Nevada law (even though we don't currently sell data) and we will record your preference in case our practices change. To do so, please contact us with your request (see Contact Us). We will verify your identity and respond in accordance with Nevada law.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, as outlined in this Privacy Policy, and for legitimate business or legal reasons. The criteria used to determine our retention periods include:

Duration of Use: We will keep your information for as long as you maintain an account with us or use the Services so that we can provide the Services to you. For example, your profile information and course records will be kept while your account is active. If you are actively engaging in our SAT prep program, we retain your data to track progress and performance.
Service and Business Needs: Even after you stop using our Services or deactivate your account, we may retain certain information to complete any outstanding obligations (such as retaining your email if you asked to be notified of a future course session), to resolve disputes or queries you might have, and to ensure we have an accurate record of your dealings with us in case of any complaints or challenges.
Legal Obligations: We retain personal information as necessary to comply with our legal obligations. For example, records of financial transactions are kept for accounting and tax purposes as required by law. If you made a purchase, we may keep a record of that purchase for several years for tax and financial auditing. Likewise, communications with you might be retained if needed to comply with consumer protection laws or to evidence consent (like keeping records of who agreed to what terms or communications preferences).
Dispute Resolution and Enforcement: If you ever had a dispute with us or if we reasonably suspect potential legal issues, we might retain relevant information as required to resolve the issue or as directed by law enforcement or legal counsel. For instance, if we banned an account for fraud or misuse, we might keep certain data to prevent that user from re-registering or to defend our actions if challenged.
Backup and Archiving: It's common that data may persist in backups or archives for a period of time beyond active use. We maintain backup systems to ensure service continuity and disaster recovery. These backups are securely stored and are only accessed if needed for restoration purposes. Data in backups may take some time to cycle out as new backups replace old ones.

When we no longer have a business need or legal reason to keep your personal information, we will securely delete it or anonymize it (so that it can no longer be associated with you). For example, we might aggregate and de-identify usage data so it can be used for statistical purposes without identifying you, and then delete the identifiable data.

In more concrete terms, here are a few examples of retention periods:

User account data is generally kept until you request deletion or for a defined period of inactivity, after which we may delete or anonymize it in accordance with our data retention schedule.
Inactive accounts: We might consider an account inactive after a certain period (e.g., 2 years without logging in) and may then contact you to see if you want to keep it. If not, we might delete or anonymize the account data.
Communications (customer support emails, chat logs) might be retained for a couple of years after resolution to help us if you reach out again or for training and audit purposes.
Web analytics data is typically aggregated and kept for a few years to analyze trends over time, though raw logs might be rotated or deleted sooner.
Recordings of tutoring sessions or calls, if any, will be retained for a limited time unless we need them longer (for instance, we might delete routine tutoring session recordings after one year, but keep a recording that is part of a disciplinary investigation until that matter is closed).

We strive not to keep personal data longer than necessary. If you have specific questions about our data retention practices for different types of data, you can contact us for more information.

Security of Your Information

The security of your personal information is very important to us. We implement a combination of technical, administrative, and physical safeguards designed to protect your information from unauthorized access, disclosure, alteration, and destruction. Here are some measures we take:

Encryption: We use industry-standard encryption protocols to protect sensitive data. For example, our websites and apps are typically served over HTTPS, which encrypts information transmitted between your device and our servers. If you provide payment information, our payment processors will ensure that financial data (like credit card numbers) is encrypted during transmission and storage. We also encrypt certain sensitive information at rest in our databases, especially things like passwords (which are stored using one-way hashing algorithms) and any sensitive personal identifiers.
Access Controls: We limit access to personal information to employees, contractors, and service providers who need that access to perform their job duties or provide services. For instance, a customer support agent might have access to your account contact info to assist you, but not to your payment info (except perhaps the last four digits of a card for reference). All such personnel are bound by confidentiality obligations. We employ access control mechanisms such as multi-factor authentication for our internal systems, role-based access permissions (so staff only see what they need), and regular review of who has access to what.
Training and Policies: Our team members are trained on data privacy and security best practices. We have internal policies in place to govern how we handle user data and to respond to potential security incidents. We strive to ensure that privacy and security are considered at every stage of our operations (often referred to as 'privacy by design' and 'security by design').
Network and System Security: We maintain up-to-date security measures to protect our network and systems. This includes firewalls, intrusion detection and prevention systems, anti-malware solutions, and continuous monitoring for vulnerabilities or unauthorized access attempts. We keep our software and infrastructure updated with security patches to reduce risks of exploitation. We also routinely perform security assessments and vulnerability scans, and may employ third-party security experts to audit or penetration-test our applications.
Data Storage and Isolation: Personal data is stored in secure cloud databases with robust security controls. We may separate certain types of data to add layers of protection (for example, storing identifying info separately from usage data and linking them with anonymized IDs). Backup data is encrypted and stored securely. When we use third-party services (such as cloud hosts), we choose reputable providers with strong security track records and we implement our own encryption or security wrappers around those services where appropriate.
Payment Security: Any payment transactions will be processed in compliance with Payment Card Industry Data Security Standards (PCI-DSS). As noted, we do not store full payment card details on our systems; instead, we rely on accredited payment processors. This reduces the risk since even a compromise of our system would not expose sensitive financial data.

Despite all these precautions, it's important to recognize that no method of transmission over the Internet or method of electronic storage is 100% secure. While we are committed to protecting your data, we cannot guarantee absolute security. Cyber threats evolve rapidly, and while we work hard to protect our systems, there is always some risk that unauthorized access, hacking, hardware or software failure, or other factors could compromise the security of user data. You also play a role in protecting your information. We encourage you to use a strong, unique password for your account and to keep it confidential. If you suspect any unauthorized activity or breach of your account, please notify us immediately.

In the unfortunate event of a data breach that affects your personal information, we will act promptly to mitigate the impact and will notify you and/or relevant authorities as required by law. We have an incident response plan in place to handle such situations, which includes identifying and fixing the vulnerability, assessing the scope of impact, and communicating with affected parties.

Third-Party Links and Social Features

Our Services may contain links to websites or applications that are operated by third parties (for example, a blog post on our site might link to an external resource, or we might reference a useful College Board page for SAT registration). In addition, as discussed, our site may include social media features or integrate with third-party platforms. It's important to note that this Privacy Policy does not apply to any third-party websites or services that we do not own or control. Once you leave our Platform or interact with a separate service, their privacy policies and terms will govern your use of those sites or services.

External Websites: If you click on a link to an external website, you will be directed to a site that is not under our control. For example, if you follow a link to a partner college's site or to an educational content provider's site, any information you provide on those pages is not handled by us. We are not responsible for the privacy practices of these other sites. We recommend that you review the privacy policy of any website you visit, especially before providing any personal information. A link to a third-party site on our Platform is not an endorsement of that third party or its privacy/security practices; it's provided for convenience or reference.
Social Media Pages and Features: We maintain official pages or accounts on various social media platforms (such as Facebook, Twitter, Instagram, YouTube, LinkedIn, etc.). If you visit or interact with our official pages on those platforms, the information you submit or that is visible on your profile may be viewed by us and by others according to the platform's privacy practices. For example, if you post a question on our Facebook page, we (and anyone else with access to that page) can see it. The platform's privacy policy and your privacy settings on that platform will dictate what information may be collected and accessible. We might use information you make available on social media (like posts about our Services) to respond to you or to improve our Service, but always in compliance with the platform's terms of use.
OAuth and Third-Party Login: As described earlier, you might have the option to log into our Platform using third-party login credentials (like Google Sign-In). If you choose to do so, you'll be sharing certain information from that third-party account with us (for example, your name and email from Google). Conversely, that third party may know that you have an account with us and might receive technical info (like the fact you logged in, your IP, etc.) during the authentication process. These interactions are governed by the third party's privacy policy. We use the information provided through OAuth solely for authentication and account creation purposes (unless we explicitly ask for more permissions and you grant them, which is not typical for our Service needs).
Public Forums and User-Generated Content: Our Platform may offer publicly accessible blogs, forums, community question boards, or comment sections. If you contribute content to these areas (such as posting a comment or a question on a discussion board, or posting a testimonial on a public wall), be aware that any personal information you submit there can be read, collected, or used by other users or the general public. For example, if you post your email or phone number in a forum reply, you might receive unsolicited messages from others, which we cannot control. We strongly urge you not to post any sensitive personal information (like full name, contact info, ID numbers, financial info, etc.) in any public forum associated with our Services. Use caution and good judgment when sharing information in these contexts. If you do choose to post personal information publicly, you do so at your own risk.
Removal of Public Posts: If you wish to remove a posting you've made in a public area of our site, in some cases you can do it yourself (for example, by deleting your comment if the interface allows it). If you cannot remove it, you may contact us for assistance. We will attempt to remove or anonymize your content from public view upon request, but please note that we cannot guarantee complete removal of content that has been reposted by others or archived by third parties (for example, if someone else quoted you or if an internet archive saved a snapshot).
Third-Party Content Integration: Occasionally, we might embed content from third parties in our site (such as a YouTube video player for relevant videos, or an embedded map or form). These third-party content providers might collect data about your browser or activity through their embedded elements, even if you do not directly interact with them. For instance, playing an embedded YouTube video on our site means YouTube's cookies and data collection apply. We try to minimize such integration and will often provide them as links instead of embeds, but when we do embed, we will do our best to signal whose content it is. Again, interacting with these features may share certain information with the third-party provider as if you visited their site/app directly.

In summary, any time you leave our domain or interact with a third-party service via our Platform, your information will be subject to that third party's rules. We encourage you to familiarize yourself with the privacy practices of every external service you use. If you have concerns about data that has been shared with a third party via our Platform, please contact us and we will try to provide any available information or assistance.

Children's Privacy

Protecting the privacy of children is especially important to us. Our Services are generally intended for high school students (and older) preparing for the SAT or related exams. We understand, however, that younger students or siblings might sometimes engage with our content, and parents might involve their children. We strive to comply with all applicable laws including the Children's Online Privacy Protection Act (COPPA) and relevant state laws regarding minors.

No Collection from Children Under 13 Without Parental Consent: We do not knowingly solicit or collect personal information online from children under the age of 13 without verifiable parental consent. Our Platform and content are not directed at children under 13 as the primary audience. If you are under 13, please do not register an account or provide personal information on our site without a parent or guardian's involvement.

If a child under 13 wishes to use our Services (for instance, some very advanced middle school students may start SAT prep early), a parent or legal guardian must contact us or facilitate the registration. In educational contexts, sometimes a school or teacher may provide consent on behalf of parents for the online collection of students' data strictly for educational use (as permitted by COPPA in an educational setting). In such cases, we rely on the school to obtain and provide the necessary consent.

Parental Involvement: For any user under 13, we require a parent or guardian's consent and involvement. A parent or guardian should create the account for the child or otherwise clearly consent to the child's use. We may ask for the parent/guardian's contact information to verify consent and communicate about the child's account. The parent will have control over the child's account and can review or request deletion of the child's personal information at any time (see below).

Information Collected from Children: With proper consent, a child user will typically provide the same types of information as described in Information You Provide to Us. This might include the child's name, age, grade, contact info (often parent's email rather than the child's direct email), and educational details. We will only use and share the child's information as necessary to provide the Services -- for example, to set up tutoring sessions, track progress, and allow parent-teacher-tutor communications -- and for internal purposes like improving our courses or ensuring safety. We do not use children's personal information for marketing or advertising purposes. That means, for instance, we wouldn't send promotional emails to a child or serve targeted ads based on a child's profile. Any marketing communications about our programs would be directed to the parent/guardian or to the school, not to the child.

No Selling of Children's Data: We do not sell the personal information of minors under 16 years of age. In fact, we treat it with heightened care. Any sharing with third-party service providers (e.g., for providing the service) will be done with strict safeguards and only for service delivery (for example, a video platform for hosting a class session).

Parental Rights: If you are a parent or legal guardian of a user under 13 (or under 18, for certain rights), you have the right to:

Review the Information: You can request to review any personal information we have collected about your child. This could include the contents of their profile, usage history, or any personal details given. We will take steps to verify you are the parent or guardian (such as requiring some identification or information that only the parent would know, since we might have parent info on file from the consent process).
Request Deletion: You may request that we delete personal information collected from your child. Note that deleting certain data might mean we have to close the child's account (for instance, if it's necessary to maintain an account). If you request deletion, we will remove the child's personal information from our active databases. However, as with all deletion requests, there could be some residual information in backups or logs which will be cleaned up in due course, and we may retain data if required for legal reasons (like a record of consent given or a transaction made).
Refuse Further Collection or Use: At any time, you may refuse to permit us to collect further personal information from your child or to use the information we have in a material way. For example, if you previously consented but later change your mind, contact us and we will cease any new data collection from the child (aside from what's needed for safety or legal compliance) and discuss options for data handling (like anonymizing existing data).

To exercise any of these rights, please contact us via the methods in Contact Us. Provide your name and the child's account information (name, email, username, etc.) so we can locate the records, and let us know what you want to do (review, delete, etc.). We may need to take steps to verify your identity and relationship to the child, to ensure that we're not giving information to someone impersonating a parent.

Children Between 13 and 18: Our policy above focuses on under 13 due to COPPA. For minors between 13 and 18, we generally allow them to use the Service with the understanding that they may need parental permission to enter into certain agreements or make purchases. We encourage parents of teenagers to be involved in their online learning and to discuss data privacy with them. Teenagers may have rights under state laws like California's privacy laws or the California 'Eraser' law (which allows minors to request deletion of content they posted publicly). If you are under 18 and a registered user in California, you can request removal of content or information you have publicly posted on our Platform by contacting us. We will make reasonable good faith efforts to remove that content (although complete or comprehensive removal from the Internet cannot be guaranteed, especially if it was reposted by others).

Educational Privacy (FERPA): If we have agreements with schools or districts to provide our Services to K-12 students, we also comply with the Family Educational Rights and Privacy Act (FERPA). Under FERPA, schools have certain obligations to protect students' education records. In such cases, we consider any student data provided by the school (or collected on the school's behalf) to be the property of the school/district. We use it only for the purposes permitted by the school and FERPA (i.e., to provide the educational service). We do not use or disclose FERPA-protected information for any other purpose except as directed by the school or as allowed by law. Parents looking to exercise rights under FERPA (like reviewing or correcting a student's education records) should contact their school directly, and we will assist the school as needed in fulfilling those requests.

In summary, we are dedicated to safeguarding children's personal information and complying with youth privacy laws. If you, as a parent or guardian, have any questions or concerns about your child's use of our Services or our data practices with respect to children, please reach out to us. We are here to work with you to ensure a safe learning environment.

Changes to this Privacy Policy

We may update or modify this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes, we will notify users as required.

Notification of Changes: If we make material changes to this Privacy Policy, we will provide a prominent notice to inform you. This may include posting a notice on our website's homepage or within the Platform, and/or sending an email notification to the email address associated with your account. The notice will explain the key changes and direct you to the updated policy. For minor updates that do not significantly affect your rights (such as clarifications or improvements to wording), we may simply update the Privacy Policy and change the 'Effective Date' above to let you know the date of the latest revision.
Effective Date: At the top of this Privacy Policy, we list the effective date. Any changes will become effective when the revised Privacy Policy is posted on our website or on the Platform, unless stated otherwise. In the case of significant changes, we may provide an advance notice period (for example, informing you a reasonable time before the new policy becomes effective) so you have the opportunity to review the changes. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
Your Continued Use Constitutes Acceptance: If you continue to use our Services after the updated Privacy Policy has become effective, it means you accept the changes. If you do not agree with the changes, you should discontinue use of the Services and can request us to delete your personal information or close your account if you want (as per your rights outlined above).

We will not make changes that have a retroactive effect on your privacy rights unless legally required to do so, and if such a scenario occurs, we would specifically inform you.

Contact Us

If you have any questions, concerns, or comments about this Privacy Policy or our privacy practices, or if you wish to exercise your rights and choices as described above, please do not hesitate to contact us. We are here to address your inquiries and support your privacy needs.

Contact Information:

Email: You can email our privacy team at privacy-academy-us@elice.io. Please include 'Privacy Inquiry' or a similar subject line so we can route your email properly. If you are exercising a specific right (like a data access or deletion request), please mention the nature of your request in the email.
Mailing Address: You may also contact us by writing to us at the following address:

1730 Minor Ave, Suite 1050, Seattle, WA 98101
Telephone: For privacy-specific inquiries, you may call us at (+82) 070-4633-2015. This is a general support line; please ask for or select the option for privacy or data protection inquiries. Our support team may first attempt to assist, and will escalate your call to our privacy officer or appropriate staff if needed.

Online Form: We may provide an online form on our website for submitting privacy requests or questions. If available, you can find the link on our Privacy Policy page or our Help/Support section.

We will endeavor to respond to any privacy-related inquiry within a reasonable timeframe. If you are contacting us to exercise a specific legal right (such as those described in Your Rights and Choices or State Privacy Rights), please provide sufficient information for us to verify your identity (as described above) and understand the scope of your request. If you have any questions about how to make a request, we are happy to guide you through the process.

Accessibility: This Privacy Policy is written in English. If you require this Privacy Policy in an alternative format or another language, please contact us and we will do our best to accommodate you. We are committed to making our privacy communications accessible to individuals with disabilities. For example, this policy can be provided in a large print, audio, or Braille format upon request. Our website is designed to be compatible with screen readers, so visually impaired users can review this policy online. If you encounter any accessibility barriers with this Privacy Policy, let us know and we will work to promptly address them.

Thank you for taking the time to read our Privacy Policy. We value your trust and are dedicated to safeguarding your personal information while providing you with excellent educational services.