Privacy Policy

1. Information We Collect

a. Information You Provide

We collect information that you provide directly to us, including:

• Account registration information (email only)
• Profile information (educational background, test scores) - only collected from students who participate in our SAT Score Guarantee Program
• Payment information when purchasing services
• Communications with us

b. Automatically Collected Information

When you use our services, we automatically collect information that does not reveal your specific identity but may include:

• Log and Usage Data: Service-related, diagnostic, usage, and performance information including:
  • IP address
  • Date/time stamps of your usage
  • Pages and files viewed
  • Search queries
  • Feature usage patterns
  • System activity and error reports
• Device Data: Information about your device including:
  • Device and application identification numbers
  • Hardware model
  • Browser type and settings
  • Operating system
  • Internet service provider and/or mobile carrier
  • System configuration information
• Location Data: Information about your device's location, which can be either precise or imprecise, collected through:
  • GPS technology
  • IP address-based geolocation
  • Other location-tracking technologies

  You can opt out of location data collection by adjusting your device settings, though this may limit certain Service features.

This information is primarily used to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

2. How We Use Your Information

We process your information for various purposes, depending on how you interact with our Services:

• Account Management: To facilitate account creation, authentication, and maintenance of your account in working order
• Service Delivery: To provide and improve our services, including personalizing your experience and processing your payments
• Marketing and Communications: To send you updates and promotional communications in accordance with your marketing preferences (you can opt out of marketing emails at any time - see "Your Rights" section)
• Security and Protection:
  • To maintain the security and operation of our Services
  • To monitor and prevent fraud
  • To protect vital interests and prevent harm
• Analytics and Improvement:
  • To analyze and improve our platform
  • To evaluate the effectiveness of our marketing and promotional campaigns
  • To better understand how to provide relevant services and communications
• Legal Compliance: To comply with legal obligations and respond to legal requests

We only process your information when we have a valid reason to do so. You can learn more about your privacy rights and how to exercise them in the "Your Rights" section below.

3. Legal Bases for Processing Your Information

We only process your personal information when we have valid legal reasons to do so under applicable law. The legal bases we rely on depend on your location:

For EU and UK Users (GDPR)

Under GDPR and UK GDPR, we rely on the following legal bases:

• Consent: When you have given explicit permission for us to process your data for a specific purpose. You can withdraw this consent at any time
• Legitimate Interests: When processing is necessary for our legitimate business interests, provided these interests don't override your rights. Examples include:
  • Sending information about special offers and discounts
  • Supporting our marketing activities
  • Diagnosing problems and preventing fraud
• Legal Obligations: When we need to comply with law enforcement, regulatory requirements, or legal proceedings
• Vital Interests: When necessary to protect your vital interests or those of others, such as in emergency situations

For Canadian Users

We primarily process your information based on:

• Express Consent: When you've given specific permission
• Implied Consent: When permission can be reasonably inferred

In certain exceptional cases, Canadian law permits processing without consent, including:

• When collection is clearly in an individual's interests and consent cannot be obtained in time
• For fraud detection and prevention
• For legitimate business transactions meeting specific conditions
• When processing insurance claims
• To identify injured, ill, or deceased persons and communicate with next of kin
• To investigate potential financial abuse
• When collection with consent would compromise information accuracy or availability
• To comply with legal requirements (subpoenas, court orders, etc.)
• For information produced in professional or employment contexts
• For journalistic, artistic, or literary purposes
• When information is publicly available as specified by regulations

4. Information Sharing

We may share your information in the following situations:

• Service Providers: With third-party vendors, consultants, and service providers who assist in our operations
• Legal Requirements: With law enforcement or other authorities if required by applicable law, regulation, or legal process
• Business Partners: With business partners only with your explicit consent
• Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company

In all cases, we take reasonable steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

5. Data Security

We have implemented appropriate technical and organizational security measures designed to protect your personal information. These measures include:

• Secure data storage and processing systems
• Encrypted data transmission
• Access controls and authentication procedures
• Regular security assessments and monitoring

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security measures.

While we strive to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

6. Data Retention

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

• Account Information: We retain your personal information for the duration of your account with us
• Legal Requirements: We may keep data longer if required by law (e.g., tax, accounting, or other legal requirements)
• Data Deletion: When we have no ongoing legitimate business need for your personal information, we will either delete or anonymize it
• Backup Archives: If deletion is not immediately possible (e.g., in backup archives), we will securely store and isolate your information until deletion is possible

7. Your Rights

General Rights

You have the right to:

• Access and obtain a copy of your personal information
• Correct inaccurate data
• Request deletion of your data
• Object to processing of your data
• Withdraw your consent at any time
• Opt out of marketing communications

Additional Rights for Specific Regions

Users in certain regions (like the EEA, UK, Switzerland, and Canada) have additional rights under applicable data protection laws, including:

• The right to restrict the processing of your personal information
• The right to data portability
• The right not to be subject to automated decision-making
• The right to complain to your data protection authority:
  • EEA residents can contact their Member State data protection authority
  • UK residents can contact the UK data protection authority
  • Swiss residents can contact the Federal Data Protection and Information Commissioner

Managing Your Account

You can manage your account information and preferences in the following ways:

• Account Settings: Log in to your account settings to review or update your information
• Account Termination: You can request to terminate your account through your account settings. Upon termination:
  • We will deactivate or delete your account and information from our active databases
  • We may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our terms, or comply with legal requirements

Marketing Communications

You can control your marketing preferences:

• Click the unsubscribe link in any marketing email we send
• Contact us directly to opt out of marketing communications
• Note: You may still receive service-related messages necessary for account administration and service requests

To exercise any of these rights, please contact us using the contact details provided in the "Contact Us" section below. We will consider and act upon any request in accordance with applicable data protection laws.

Please note that withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal, and in some cases, we may continue to process your information if we have legitimate legal grounds to do so.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. These technologies help us:

• Remember your preferences and settings
• Understand how you interact with our Services
• Analyze and improve site performance
• Provide personalized content and recommendations
• Measure the effectiveness of our communications

You have control over cookies and can manage them in several ways:

• Browser Settings: Configure your browser to block or notify you about cookies
• Cookie Preferences: Adjust your cookie preferences through our cookie consent tool
• Private Browsing: Use your browser's private or "incognito" mode

Note: Blocking or deleting cookies may affect your experience and limit certain features of our Services.

9. Children's Privacy

Our Services are not intended for children under 13 years of age. We do not knowingly collect or solicit personal information from anyone under 13.

• Age Restriction: If you are under 13, please do not attempt to register for the Services or send any personal information to us
• Parental Consent: If you are between 13 and 18 years old, you must have permission from a parent or guardian to use our Services
• Information Collection: If we learn that we have collected personal information from a child under 13, we will take steps to:
  • Delete that information as quickly as possible
  • Prevent further collection from the child
  • Ensure proper parental consent for any future collection

If you believe we might have collected information from a child under 13, please contact us immediately at [email protected]

10. Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time. When we make changes:

• Notice: We will post the updated Privacy Policy on this page and update the "Last Modified" date
• Material Changes: For significant changes:
  • We will notify you through email or a prominent notice on our Services
  • We may request you to actively acknowledge and accept the changes
• Continued Use: Your continued use of the Services after changes become effective constitutes acceptance of the updated Privacy Policy

We encourage you to review this Privacy Policy periodically to stay informed about our information practices and your privacy rights.