Effective Date: 1/1/2024

This Privacy Notice (the “Privacy Notice”) governs the manner in which Clarion Educational Services LLC, and its related and affiliated entities, unless otherwise stated or otherwise governed by such entity’s own privacy notice (“Company”) collects, uses, maintains, and discloses information collected from users (each, a “User”) of its www.clarioned.com website, applications, and technology platform, and any derivative or affiliated websites on which this Privacy Notice is posted, linked, or referenced (collectively, the “Site”). The Site is owned and operated by Company. Please note that this Privacy Notice covers Company's practices regarding information collected from/through its Site. Please read this Privacy Notice carefully to understand how we handle your information. By using the Site, you agree to the terms of this Privacy Notice. You shouldn’t use the Site if you don’t agree with this Privacy Notice or any other agreement that governs your use of the Site.

Information We Collect And Receive

The categories of information that are collected will depend upon the nature of your interaction(s) with us and the Site. Below are examples to help you better understand the data we collect.

Information you provide to us. We collect a variety of information that you provide directly to us in connection with your use of the Site and/or our services. While parts of the Site may not require you to provide any information that can directly identify you (such as if you choose to browse the website without logging in), the specific types of information we collect will depend upon how you use the Site and the information you choose to provide. The types of data we collect directly from you include:

Contact information. When you submit an inquiry to us through the Site or otherwise, we collect your name, email address, and phone number if provided, along with general information about the nature of your inquiry. If you create an account through the Site, we will also collect your username, password, mailing address, and other information related to providing you services through the Site.

Payment information. If you make a purchase with us, we (or our business partner(s) who process payment transactions for us) may collect your billing or other financial information in order to process the transaction(s). We do not store sensitive cardholder data, such as full credit or debit card numbers, card authentication data, or sensitive bank account information.

Student data. We collect personal information about the students to whom we provide services. This information includes, but is not limited to: name, school, graduation year, extracurricular activities, and university admissions. Company also collects the results of academic exercises and standardized tests. We use these results in a variety of ways to improve our services, for example by developing machine learning models.

Information about third parties that you provide to us. A User may also provide personally identifiable information about others, such as emergency contact information for notification in the event a situation requires it, or, if you choose to use our referral service to refer a friend to our Site, then you may provide your referral’s name and email address. If you submit any personal information about another individual to us, then you are responsible for making sure that you have the authority to do so and to allow us to use their personal information in accordance with this Privacy Notice.

Information through surveys, testimonials, comments, reviews, and blogs. You may decide to participate in a survey, to provide a review, to provide a testimonial, to comment on a blog or social media post, etc. If you decide to participate or comment, then you may provide certain information that may include personal information. In addition, we may post customer testimonials/comments/reviews on our Site.

Passively-collected information. We collect certain information as you visit or interact with our Site, such as the following:

Internet and electronic network activity information, such as device and usage information. We may collect information about your browser type, language preference, referring site, subsequent site, and date/time of each visitor request. The purpose in collecting non-personally identifying information is to better understand how Users use the Site. We may collect information about your operating system, Internet Service provider information and IP addresses and other device identifiers, such as mobile device information. In addition, we may collect information about your use of the Site, unique views, originating sites, etc., including through the use of tracking technologies (See section pertaining to Tracking Technologies for more information).

Analytics information. We may use certain third-party services to assist us in analysis, auditing, research, and reporting regarding the Site. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, we may use Google Analytics to help collect and analyze certain information for the purposes discussed in this Privacy Notice. You may opt out of the use of cookies by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Demographic information and information about your interests. We may collect information such as your zip code, gender, age, income, household or lifestyle information, and information about your interests and preferences.

How We Use Information

We may use personally identifiable information collected through the Site for the following reasons:

• for the specific purposes for which the information was collected;

• to fulfill a contractual obligation;

• to communicate to Users, including regarding products and services;

• to maintain and improve its products, services, and sites;

• to provide support;

• to inform Users of offerings that may be of interest;

• to process payments;

• for business planning, marketing, advertising and sales purposes;

• for information security purposes;

• to defend its legal rights;

• to efficiently maintain its business; and

• to comply with applicable law.

Information Sharing

We may share information that we collect about you in the following ways:

With our affiliates, service providers and third-party vendors. We may share information with companies affiliated with us. We contract with select third party vendors to provide services on our behalf, for example, services such as email, hosting, cloud storage, maintenance, backup and analysis, communications software, marketing, business strategy, banking, payment processing, professional services, background checks, etc. We also may share non-personal information (such as aggregate user statistics, de-identified information, demographic information, etc.) with third parties such as advertisers, content providers, and analytics providers.

To the extent required by law or to protect the company or others. We may disclose personally identifiable information at the request of law enforcement or governmental agencies or in response to subpoenas, court orders, or other legal process, to establish, protect, or exercise our legal or other rights or to defend against a legal claim or as otherwise required or allowed by law. We may disclose personally identifiable information in order to protect the rights, property, or safety of a User or any other person. We may also disclose personally identifiable information to investigate or prevent a violation by User of any contractual or other relationship with us or the perpetration of any illegal or harmful activity.

In connection with any business acquisition, sale, or merger, or in connection with investor relations. We may disclose or transfer personally identifiable information collected from Users in connection with or in contemplation of a sale of its assets or business or a merger, consolidation, or other reorganization of its business. We may also disclose aggregate, anonymous data based on information collected from Users to investors and potential partners.

Users may always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain Site-related activities.

Cookies and Other Tracking Technologies/Analytics

We and our analytics and marketing providers may use technologies such as cookies, beacons, tags, and scripts (collectively “cookies”), to analyze trends, administer the Site, track Users’ movements around the Site, and to gather demographic information about our User base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

We use cookies for tracking page view/usage (log data), estimating audience size and usage patterns, services metadata, device information, location information, saving Users’ preferences and settings information, advertising new content that relate to your interests, keeping track of advertisements and search engine results, and for authentication. Each User can control the use of cookies at the individual browser level by adjusting your browser settings. Please see the links here for guidance on how to modify your web browser’s settings on several popular browsers: Google Chrome, Apple Safari, Microsoft Edge, Internet Explorer, and Mozilla Firefox.

If you choose to block all cookies (including essential cookies), you may still use our Site, but your ability to use some or all features or areas of our Site may be limited.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream, and/or field input data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve marketing, analytics, or site functionality.

Certain portions of the Site include Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our Site. These Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

We, along with third-party vendors (including Google), may use first-party cookies (such as the Google Analytics and Facebook Analytics cookies) and third-party cookies (such as the DoubleClick cookies) to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website.

Third Parties, with whom we partner to provide certain features on our Site or to digital advertising based upon your Web browsing activity, may use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs, which can be accessed through the web browser links referenced above.

Your Choices Regarding Your Information

General requests: To exercise any available rights regarding your information or privacy preferences that may be properly addressed to us, you may contact us at scott@clarioned.com. This includes any requests to stop receiving communications from us, to delete or modify your information, or to take other action regarding your information.

Do Not Track and other similar signals: Some internet browsers incorporate a “Do Not Track” or other similar feature; however, given that there is not a uniform way for browsers to communicate this signal, the Site does not currently support these signals.

Cookies and Internet-based Advertising: You may stop, restrict, or remove the placement of cookies on your device by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners. These may be accessed at sites such as www.aboutads.info/choices.

Data Retention

We store the information collected as described in this Privacy Notice for as long as you are a User of the Site and/or as necessary to fulfill the purpose(s) for which the information was collected, to provide services through the Site, to resolve disputes, to pursue legitimate business purposes, to enforce our agreements, to establish legal defenses, to prevent fraud, and to comply with applicable laws. These needs can vary based upon the data type and the context of the services, and thus the retention will vary as well.

Security of Information

We disclose potentially personally-identifying and personally-identifying information based upon user consent only to those of its employees, contractors, and affiliated organizations that (i) need to know that information in order to process transactions on our behalf or to provide tutoring services, and (ii) that have agreed not to disclose it to others. We take all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.

Information about each User that is maintained on our systems is protected using industry standard security measures. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at scott@clarioned.com. However, no security measures are perfect or impenetrable. We cannot guarantee that the information submitted to, maintained on, or transmitted from its systems will be completely secure, and are not responsible for the circumvention of any privacy settings or security measures relating to the Site by any User or third parties.

Links to Third Party Sites

Please note that the Site may contain links to other websites. These linked sites may not be operated or controlled by us. We are not responsible for the privacy practices of these or any other Sites, and you access these Sites entirely at your own risk. We recommend that you review the privacy practices of any other Sites that you choose to visit.

Children’s Privacy

Our Site and products are specifically designed to function without third party access to a child's personal information. Our site does not collect or retain any personal information from children except as needed to facilitate tutoring for that student, who may be a minor. We are committed to complying fully with the Children's Online Privacy Protection Act of 1998 ("COPPA") and any other applicable laws. Other than free information and materials that do not require any registrations or identifying information, the Site is not directed at children under 13 years of age, and we do not knowingly collect personally identifiable information from children under 13 years of age online. Parents or guardians of children under 13 years of age may review or have deleted any personal information previously provided by the child, parent, or guardian that is ultimately collected by us, if any. If you seek to review or delete such information, contact us at the below phone number or email address indicating what you would like to have done and we will contact you for purposes of taking the requested action, including but not limited to refusing to permit the information’s further collection or use.

International Users

We are based in, and this Site is hosted in, the United States of America. If you are located outside of the United States, then you may be in a location with laws governing data collection and use that may differ from U.S. law. You understand that by being a User of the Site and/or by entering into an agreement with us as a customer, that you consent to the collection, storage, and processing of your data in the U.S.

We rely on different lawful bases for collecting and processing personal data about you depending upon how you use the Site, including your consent, contractual necessity to provide the services and operate the Site and the business, to meet contractual and legal obligations, to protect the security of our systems and our Users, and/or to fulfill other legitimate interests.

Please refer to the Your Choices Regarding Your Information section to review the rights you have regarding your data. Additionally, your local laws may permit you to request that we take certain action regarding requests related to data. We will consider all requests and will provide a response within the time period required by applicable laws, but reserve the right to assert that any such laws do not apply. We may request that you provide us with additional information in order to confirm your identity before responding to your request.

Changes to this Privacy Notice

We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes, then we may notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. Please review this Privacy Notice periodically. Your continued use of the Site after any such change(s) signifies your acceptance of any changes.