We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and internationally, and we are responsible as “controller” of that personal information for the purposes of those laws.
- What information do we collect about you?
First of all, we want to make clear that we do not collect any personal information from you that you don’t provide to us.
When you sign up to be a user on our Sites, we may ask you for the following information about our users (“Personal Information”):
- First and last name
- Email address(es)
- Phone number
- Date of Birth
- Country, State/Province, and City of Residence
- Physical Address
- Countries of Citizenship
- College/Career Application Information (Degree type, enrollment year, application year, high school graduation year, academic information, current school, preferred courses, current grade, financial aid information, diploma information, academic interests, preferred college choices, and related information).
If you choose to purchase or subscribe to a feature or Service of Prepory that requires a fee, you will be required to provide us with your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and similar data (your “Payment Information”).
If you choose to subscribe to the Services, “Personal Information” may also include video and audio recordings of phone calls and videoconferences hosted by us between you and our employees and/or coaches (“Recordings”). These Recordings are maintained for safety and quality assurance purposes and are deleted automatically within one (1) week of being recorded.
Like most websites, we may use automatic data collection technology when you visit the Sites to record information that identifies your computer, to track your use of our Site, and to collect certain basic information about you and your surfing habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Site and the Services (the “Usage Information”).
We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. You can reject cookies by following the directions provided in your Internet provider’s “help” file. If you reject cookies, you may still visit the Sites, but may not be able to use some areas of the Sites and/or the Services.
We do not collect Personal Information in this way, but if you’ve provided us with Personal Information, we may associate that information with the information that is collected automatically. Automatic data collection may be performed on our behalf by our services providers.
- How will we use your information?
- To identify you when you sign in to your account;
- To respond to your requests and to provide you with the Services;
- To otherwise fulfill our performance duties under any contract we have with you;
- To transmit to Prepory team members and coaches to allow those individuals to help us provide you with the Services;
- To respond to your inquiries and contact you about changes to the Site and/or the Services;
- To send you notices (for example, in the form of emails, mailings, and the like) regarding products or services you are receiving, and for billing and collection purposes;
- To send you information we think you may find useful or that you have requested from us;
- To enhance and improve the Sites or the Services, such as through personalized features and content;
- To ensure that our business policies are adhered to;
- To analyze the use of the Site and the Service and the people visiting to improve our content and Site and the Service;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
- To process authorized payments for our Services
- For any other purposes disclosed at the time the information is collected or to which you consent; and
- When will we disclose your Personal Information to third parties?
We do not disclose your Personal Information to third parties for their direct marketing purposes. However, there are instances in which we may disclose Personal Information we collect on the Site to third parties in order for us to operate the Site and provide the Services. One such third party is the Cialfo platform (www.cialfo.co), which we use to host and manage the MyPrepory platform. When you create a MyPrepory account, we may share (and you will also be personally entering) your Personal Information onto Cialfo to access MyPrepory. We will also disclose your Personal Information to your Prepory coach(es) to ensure that they can effectively help us provide you with the Services.
We only allow these recipients to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on these recipients to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. If we or all or substantially all of our assets are acquired, we expect that the information that we have collected, including Personal Information, would be transferred along with our other business assets.
- How Will We Protect Your Information?
We take commercially reasonable steps to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
- How Can You Access and Modify Your Account Information?
You can access and update the information that is stored in your user account by accessing your MyPrepory profile page. You can also update your information by e-mailing us at firstname.lastname@example.org.
- Can You Tell Me More About the Promotional Emails that I am Receiving from You?
We may send you promotional emails from time to time. These emails cover topics such as telling you more about new products and services that we offer as well as helpful tips on the college and career counseling process. If you ever wish to stop receiving promotional e-mails, you may do so by e-mailing email@example.com. You may also choose to unsubscribe from our emails by following the instructions in the bottom of the email.
- How Long Will You Keep My Personal Information?
We will keep your personal information while you have an account with us or while we are providing Services to you. After that, we will keep your personal information for as long as is necessary:
• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.
When it is no longer necessary to retain your personal information, we will delete it or anonymize it.
- How Does Prepory.com Honor Do Not Track Signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Additional Information Regarding Visitors Under the Age of 13
Additional Notice to Users Outside of the US
The Sites and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Sites or the Services, you consent to this transfer.
EU General Data Protection Regulation (GDPR) Information
If you are in the European Economic Area (EEA), you may have certain rights regarding your personal data:
Right to Access
The right to be provided with a copy of your personal information (the right of access)
Right to Rectification
The right to require us to correct any mistakes in your personal information
Right to be Forgotten
The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object
The right to object:
Right Not to be Subject to Automated Individual Decision-Making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you