This Privacy Policy applies to information collected through websites and other online channels owned and operated by EDUTrust, LLC. (“EDUTrust”) (collectively, the “Site”) that we link to this Privacy Policy.

EDUTrust is based in the United States, so any information we collect through this Site or that you provide to us will be transferred to and maintained in the United States. By using this Site and/or providing us with your information, you understand and agree that such personally identifiable information will be transferred to the United States and subject to disclosures and uses in accordance with U.S. law and as described in this Privacy Policy.

By providing personally identifiable information to us, you explicitly consent to the collections, uses, and disclosures of information described in this Privacy Policy, including the transfer of that information to the United States, and are responsible for obtaining any consent or providing any notices required for such transfer.

What information do we collect?

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We collect information from you when you register on our Site, provide information about your educational interests, or provide feedback or ask a question. Some of this information may be “personally identifiable information”, which means information that can be associated with you and can be used to identify you (“Personal Information”).

When registering on our Site, as applicable, you may be asked to enter your user id and password, name, e-mail address, mailing address, telephone number, program of interest, educational background, or other information. You may visit our Site without providing that information, but certain information will be required to register with the Site. We may also collect information about the browser and/or device that you are using to access our Site (such as the type of browser or device you are using, browser settings, and the device identification number).

The chart below describes in greater detail the types of Personal Information we collect, and how and why we collect and retain the Personal Information:

Personal Information Category Whether Category is Collected and the Source of Collection Retention Period Business or Commercial Purpose for Sharing or Use Whether This Category is Sold

A. Identifiers (including government-issued identifiers).

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar identifiers.

Yes

  • You
  • Your device
  • Our Service Providers or Business Partners

10 years

  • Provide the services you request
  • Improving our services
  • Inform you about our other services and offers that may be of interest to you
  • Meet our contractual obligations with Service Providers or Business Partners
  • Meet legal and regulatory requirements
  • Provide customer service
  • Detecting and protecting against security events and fraud

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, address, or telephone number.

Yes

  • You
  • Your device
  • Our Service Providers or Business Partners

10 years

  • Provide the services you request
  • Improving our services
  • Inform you about our other products, services and offers that may be of interest to you
  • Meet our contractual obligations with Service Providers or Business Partners
  • Meet legal and regulatory requirements
  • Provide customer service
  • Detecting and protecting against security events and fraud
  • Auditing consumer interaction & transactions

Yes

C. Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, union membership, genetic information (including familial genetic information).

No

N/A

N/A

N/A

D. Commercial information.

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No

N/A

N/A

N/A

E. Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

N/A

N/A

N/A

F. Internet or other similar network activity.

Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Yes

  • You
  • Your device
  • Our Service Providers or Business Partners

10 years

  • Provide the services you request
  • Improving our services
  • Inform you about our other services and offers that may be of interest to you
  • Meet our contractual obligations with Service Providers or Business Partners
  • Meet legal and regulatory requirements
  • Provide customer service
  • Detecting and protecting against security events and fraud
  • Auditing consumer interaction & transactions

No

G. Geolocation data.

Examples: Physical location or movements.

No

N/A

N/A

N/A

H. Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

No

N/A

N/A

N/A

I. Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

No

N/A

N/A

N/A

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

No

N/A

N/A

N/A

K. Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

10 years

  • Provide the services you request
  • Improving our services
  • Inform you about our other services and offers that may be of interest to you
  • Meet our contractual obligations with Service Providers or Business Partners
  • Meet legal and regulatory requirements
  • Provide customer service
  • Detecting and protecting against security events and fraud
  • Auditing consumer interaction & transactions

Yes

Other information collection

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Device information may or may not be personally identifiable depending upon whether it is linked to the identity of or could be used to identify the user. We may automatically log information, such as a user’s IP address, domain name, browser type, date and time of access, and other log file data. This information may be used to analyze trends or administer our Sites. We may collect statistical or non-personally-identifiable information about our users, such as which pages of our Sites are visited, how long a visitor stays on a particular page, the website from which a user came to our Site, which of our advertisements are clicked, whether email we send is opened, or similar such information. We also may collect aggregate information such as the total number of unique or return visitors to our Site, using our application, or visiting a particular page in a given timeframe. We may use this information to measure the use of our Sites and applications and to improve our content.

We may use Google Analytics, a provider of analytics tools, or a similar service to analyze information about visits to our Site. You can learn “How Google uses data when you use our partners’ sites or apps” at www.google.com/policies/privacy/partners/For information about opting out of Google Analytics please visit: https://tools.google.com/dlpage/gaoptout.

Do we use cookies

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Yes. Cookies are small files that a Site or its service provider transfers to your computer or device’s hard drive through your Web browser (if you allow) that enables the Sites or service providers’ systems to recognize your browser and capture and remember certain information. We use cookies to help us remember, understand and save your preferences for future visits, keep track of advertisements and compile aggregate data about Site traffic and Site interaction so that we can offer better Site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our Site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. We may also permit other parties to collect personally identifiable information about an individual consumer’s online activities over time and across different Websites when a consumer uses our Site.

Some Internet browsers offer what is referred to as “do not track” mechanisms for browser users to automatically signal privacy preferences to websites that they visit. Our site does not recognize these mechanisms, but you can disable cookies using your Internet browser settings. Please consult your help function for information on how to disable cookies. Note that if you disable cookies, certain features of our Site may not function properly.

What do we use your information for?

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Any of the information we collect from you may be used in one of the following ways:

  • To communicate with you and to process transactions that you may request, including the use of Personal Information to prepare your order in accordance   with your order;
  • To personalize your experience (your information helps us to better respond to your individual needs);
  • To understand how our Site is used and improve our Site (we continually strive to improve our Site offerings based on the information and feedback we receive from you);
  • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);
  • To send marketing communications and to conduct market research, if you opt to receive further communications from us;
  • To notify you of any changes with our Site which may affect you;
  • To enforce the terms of use for our Site or any other agreement you may have with us;
  • For historical, statistical or business planning purposes;
  • To prevent fraud and investigate potential misconduct;
  • To provide educational opportunities and training certification; and
  • To comply with the law and legal process.

We may use the Personal Information, and other information to compile statistics are non-specific to you and do not identify you, and to create other aggregated and anonymous information. We may use and disclose such aggregated information to maintain and improve our Site, or for any other purpose we choose.

Do we use cookies? What choices do you have about how we use your information?

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You have a number of choices regarding our collection and use of information through our Sites:

In cases where you are requested to affirmatively provide information, such as to register or to complete a form, or an application, or a survey on our Site, you may decline to do so. Please understand, however, that in some cases certain information is required to complete an application, form or survey, and if you decline to provide the information requested you may not be able to submit the application or request or to use certain functionalities of our Site(s).

If you would like to restrict the placement of cookies on your device, please see the discussion of cookies above.

In connection with your registration, or at any time after registering, you may choose whether to receive e-mail communications from us. You also can unsubscribe from receiving any commercial communications from us by following the unsubscribe instructions in any email you receive from us or changing your preferences through our Site(s). Please note that even if you opt-out of commercial communications, you may still receive transaction notices if you enter a transaction with us, notices of changes to our terms or privacy policy, or other messages that we are required to send by an applicable law.

How do we protect your information?

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We implement a variety of security measures to help maintain the safety of your personally identifiable information.

Personally identifiable information may be accessed by persons within our organization, or any of our third-party service providers, who require such access to carry out the purposes we describe in this Privacy Policy.

If you use this Site or mobile application, you are responsible for maintaining the confidentiality of any user ID and password or other access credentials that you may be provided. You should notify us immediately if any user ID and password or other access credentials we may issue you are compromised. We are not responsible for your failure to do so, or for any delay in shutting down your account after you make a report, and you are responsible for all actions taken under your user ID and password.

While we take steps to help protect the personally identifiable information we collect, no security measures can provide absolute protection. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

Do we disclose any information to outside parties?

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We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information except as described in this policy or as required by applicable law.

We may share personally identifiable information with third parties who assist us in carrying out the processing of information described in this Privacy Policy, including operating our Site, conducting our business, and servicing your account, so long as those parties agree to keep this information confidential.

We also may share your personally identifying information with any third-party, without your consent or approval and without notice to you, (i) as permitted or required by law, (ii) in connection with a corporate sale, merger, reorganization, dissolution, bankruptcy or similar event, (iii) under circumstances we believe reasonably necessary to protect the personal safety of our employees, users of the Site, or the public, (iv) to disclose information that is necessary to identify, contact or bring legal action against someone who may be violating our published policies, or (v) as is otherwise described in this Privacy Policy.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Your personally identifiable information may also be collected across websites for learning or training purposes.

Access and correction

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If you wish to request that we correct, change or remove any information about you that we may have collected, please contact us at support@edutrustnetwork.org

To help protect against fraudulent requests for access to your personally identifiable information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your personally identifiable information before granting access. For example, we may require you to verify your identity before you access your personally identifiable information.

Opting out of emails

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For communications received via email, utilize the “opt-out” functionality embedded within the email if you would like to be removed from our mailing list. Even if you, however, we may continue sending certain communications (e.g., responding to an inquiry from you, or communications related to a business transaction).

For users in certain states in the United States:

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Residents of certain states (including California) may have certain rights regarding your Personal Information under state law. This section describes privacy rights applicable to residents of certain states and explains how to exercise those rights. These rights apply only where applicable by law.

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

    • The categories of personal information we collected about you.
    • The categories of sources for the Personal Information we collected about you.
    • Our business or commercial purpose for collecting or selling that Personal Information.
    • The categories of third parties with whom we share that Personal Information.
    • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
      • sales, identifying the Personal Information categories that each category of recipient purchased; and
      • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
      • The specific pieces of Personal Information we collected about you (also called a data portability request).

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

      1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
      2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      3. Debug products to identify and repair errors that impair existing intended functionality.
      4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
      5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
      6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
      7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      8. Comply with a legal obligation.
      9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

If you choose to exercise these rights, we ask you to provide sufficient information, including the services you have used in the past, your state and country of residence, and contact information, in order for us to verify your identity and process your request. Depending on the types of requests, additional information may be requested. We will only use Personal Information provided in this context to verify the requestor’s identity or authority to make it.

You may use an authorized agent to submit a request on your behalf related to your Personal Information. If you choose to use an authorized agent, you should supply your agent with written permission to act on your behalf in relation to your request, and your agent must provide us with proof of such authorization before we process your request.

To exercise a right related to your Personal Information, please contact us by email at support@edutrustnetwork.org.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact support@edutrustnetwork.org. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you for exercising any of your state-specific privacy rights. Unless permitted by law, we will not:

      • Deny you goods or services.
      • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
      • Provide you a different level or quality of goods or services.
      • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by applicable law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Third-party links

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Occasionally, at our discretion, we may include or offer third-party products or services on our Site. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked Sites. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these Sites.

Alternative Format

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If you need to access this Policy in an alternative format due to having a disability, please contact support@edutrustnetwork.org.

Children’s Online Privacy Protection Act Compliance

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Our Site, products, and services are all directed to people who are at least 13 years old or older. We do not intend or invite people under the age of 13 to visit our Site and we do not knowingly collect or retain personally identifiable information from children under the age of 13.

Changes to our privacy policy

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If we decide to change our privacy policy, we will post those changes on this page. If we make changes to the Privacy Policy, we will revise the “Effective Date” at the top of this Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the site. Your use of our Site means that you accept the revised Privacy Policy.

Contacting us

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If there are any questions regarding this privacy policy, including how your personally identifiable information is used, if you would like to request access to or correction of your personally identifiable information, or if you wish to opt-out of receiving any communications from us, you may contact us at the address below.

EDUTrust, LLC
PO Box 55691, Lexington, Kentucky 40555

support@edutrustnetwork.org