We are Prepory Coaching Group, LLC (“Prepory,” “we”, “us,” “our”). We created this privacy policy (“Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of Prepory in connection with our online services (the “Services”), which are made available to you through our website located at www.prepory.com and on our affiliated “MyPrepory” platform located at prepory.cialfo.co (collectively, the “Sites”).

Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

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.

By visiting our Sites and/or using our Services, or by permitting your child to use our Services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use/Services.

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
  • Gender
  • 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.

We may use your Personal Information, Usage Information, and Payment Information in a manner that is consistent with this Privacy Policy and the context of our relationship with you. We will use your Personal Information and Usage Information collected through the Site for the following purposes:

  • 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
  • As otherwise specifically described in this Privacy Policy

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 CounselMore platform (www.counselmore.com), 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 CounselMore 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. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories of personal information exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

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.

We will share your Payment Information with the third party service provider (HubSpot Payments, powered by Stripe) as necessary to process your payment. The third party service provider stores your Payment Information; we do not store this information. Storage by the third party service provider of your Payment Information is subject to the privacy policies and practices of the third party service provider and is not subject to the terms of this Privacy Policy. By providing your Payment Information, you acknowledge and agree to use of such information by the third party service provider for purposes of processing your payment to us.

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.

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 info@prepory.com.

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 info@prepory.com. You may also choose to unsubscribe from our emails by following the instructions in the bottom of the email.

You may see may contain content, services, advertising and other materials on our Sites that link to websites operated by third parties. We have no control over those other sites, and this Privacy Policy does not apply to them. Please refer to the privacy policies of those sites for more information on how the operators of those sites collect and use your 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.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete it or anonymize it.

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.

Absolutely. If you have questions about this Privacy Policy, please e-mail us at admin@prepory.com with “PRIVACY POLICY” in the subject line, or mail us at the following address: 12555 Orange Drive, Suite 100A, Davie, FL 33330.

Changes To Our Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes on the Sites as soon as they go into effect. We will also provide you notice via email when we make updates to our Privacy Policy. By accessing the Site or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

Additional Information Regarding Visitors Under the Age of 13

We do not knowingly collect any personal information from visitors or users of our site who are under the age of 13. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our privacy policy by instructing their children to never provide personal information through the Internet without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at info@prepory.com, and we will endeavor to delete that information from our databases.

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

Lawful Basis of Processing: Our legal basis for collecting and processing your personal information can include (i) consent with notice, (ii) performance of a contract, (iii) to comply with our legal and regulatory obligations, (iv) for our legitimate interests or those of a third party (A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests). Please contact us using the contact details provided in this Privacy Policy (see Point #10 above) if you have any questions or concerns about the specific legal grounds in which we employ to inform our lawful basis of processing of your 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:

  • at any time to your personal information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

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

Any requests to exercise these rights can be directed to us through the contact details provided in this Privacy Policy (see Point #10 above). These requests will be exercised free of charge and will be addressed by us as early as possible and always within one month. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.