Trust & Privacy
Educo Privacy Policy
For any user under the age of 13, we must have verifiable consent from the user's parent or legal guardian (obtained by the user's school on behalf of the parent or legal guardian if the user is participating in our Services through their school, or obtained by us directly) before we collect any personal information from such user or use or disclose that personal information. Consistent with the Children's Online Privacy Protection Act ("COPPA"), we only collect personal information from a child under 13 that is reasonably necessary to provide our Services.
Parents and legal guardians are welcome to contact us at 212-347-3210 or hello@learneduco.com to review any personal information we have collected about their child, request that we delete this information, or request that we collect no further information from their child. We will verify the identity of anyone requesting information about a child under the age of 13 to confirm that the person is the child's parent or legal guardian before fulfilling the request. We do not correspond with users under the age of 13 about products, services, or events of other organizations.
We collect information through the sources described below.
Information You Provide to Us
We collect personal information and non-personal information from you (such as your or your parents' or guardians' name, address, email address, phone number, credit card number, school name, grade level, year of graduation, date of birth, GPA, the test you are preparing for, test scores, academic interests, transcripts, photos, essays, applications to schools, extracurricular activities, employer name and job title, accommodation requests, race, and military or veteran status) when you:
register for or create an account on our Sites;
call us;
purchase and use our Services or purchase the products or services of third parties that we resell;
provide or send us messages, documents, and other files and content in the course of your use of our Services;
enter sweepstakes or other promotions;
submit online forms or testimonials, or respond to surveys or questionnaires;
register for or attend events we host, sponsor, or participate in; or
provide us information by other means.
Information from Third Parties
We may collect personal and non-personal information about you (such as your name, email address, student ID number, username, grade level, school name, and courses you are taking) from third parties with whom we have a business relationship, including our organizational customers (such as schools and school districts), organizations with whom we have marketing agreements, resellers, service providers, and vendors who provide lead generation services.
We may receive information about you from users who refer you to us.
We may obtain personal and non-personal information from publicly and commercially available sources, including organizers of events you may attend.
Information Collected Automatically
We collect information (such as your IP address, device identifiers, browser type, cookies, the referring website address, and operating system) from your browser when you visit our Sites.
We, our service providers and other vendors, and our affiliates and third parties may use tracking technologies such as cookies, web beacons, pixel tags, and similar technologies to collect information about your online interactions with our Sites and our emails.
We collect information when you purchase or use our Services, including when we record online sessions, produce transcripts of online tutoring sessions, and track the drills, assignments, and practice tests that you complete online.
We may automatically record calls to our call center for quality assurance, training, and service improvement.
We may use your personal information to:
provide you with and personalize our Services, or resell to you the products and services of a third party;
create and manage your account, process your orders, and provide customer service;
maintain our internal records, comply with legal requirements, and otherwise manage our business;
send you newsletters and advertisements and otherwise correspond with you about products, services, events, and other organizations that we think may interest you (or, if an organizational customer arranged for your participation in our programs, correspond with you about our Services and events that we think may interest you);
ask for your reviews and testimonials and send you surveys and questionnaires;
include your submissions as content in our Services and marketing materials if you have provided permission;
administer sweepstakes and other promotions;
develop and display content and advertising tailored to your interests on our Sites and other sites, provide our advertisements to you when you visit other sites, and analyze the effectiveness of our advertisements;
perform research and analysis about your use of or interest in our Services, the products and services offered by others, and our Sites, and develop new products and services;
detect, prevent, or investigate illegal activity or misuse of our Services and enforce our legal rights; and
perform functions as otherwise described to you at the time of collection.
We may use non-personal information for any lawful purpose.
We may disclose your information to third parties as described below. We do not disclose your personal information to third parties for their own direct marketing purposes except as described under "Schools You Are Interested In" below.
Organizations and Persons Who Arrange for Your Participation in Our Programs
We work with schools, school districts, colleges and universities, local, state, and federal government agencies, businesses, and other organizations to provide test preparation, tutoring, and admissions counseling programs. Your organization may arrange for your participation in these programs and negotiate a special price or trial offer, or purchase or subsidize Services on your behalf. We may disclose the personal and non-personal information we collect through your participation in these programs (such as test scores, transcripts or recordings of online tutoring and class sessions, comments you leave in post-session surveys, and details regarding your usage of our programs) to the organization arranging for your access to these programs or to your parents or guardians. Your school may also require us to disclose such information to others legally entitled to access your academic records, such as your state department of education. If you use a promotion code at our Sites to create an account or add Services, we may let the source of that promotion code know that you used that code.
Third Parties Whose Products or Services We Resell
We may disclose your personal information to third parties whose products or services we resell so that these third parties can provide you their products or services. These third parties may use your personal information in accordance with their own privacy policies.
Service Providers and Other Vendors
We may disclose your personal information to our service providers and other vendors who support our operations and help us deliver our Services. Categories of service providers and vendors with whom we may share data include:
Providers of analytics and performance monitoring tools that help us understand how you interact with our Sites and platforms.
Providers of cloud infrastructure and hosting services that host our Sites and applications, provide data storage, and help ensure platform stability and security.
Content providers.
Providers of instructional services, including tutors and instructors.
Providers of customer relationship and communication platforms used to manage accounts, customer interactions, and multi-channel communications (such as email, SMS, and chat).
Providers of instructional and collaboration tools used to deliver tutoring, instruction, and virtual classroom sessions, and to support student collaboration and engagement.
Providers of marketing and advertising services that assist in delivering marketing communications, analyzing engagement, and optimizing advertising.
Providers of payment processing services.
Providers of survey and feedback platforms used to collect feedback and conduct surveys.
Providers of delivery services for physical materials.
Affiliates
We may disclose your personal information to our subsidiaries and affiliated entities.
Legally Compelled Disclosures and Safety
We may disclose personal information when compelled to do so by government authorities or otherwise as required or permitted by law, including to respond to court orders and subpoenas. We may also disclose personal information to protect the safety of others and when we have reason to believe that someone is causing injury to or interfering with our rights or property or the rights or property of others.
Business Transfer
If we or all or a portion of our business is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, personal information may be included in the transferred assets.
Authorized Disclosure
We may disclose your personal information to third parties when you authorize the disclosure.
Non-Personal Information
We may disclose non-personal information to any third party for any lawful purpose.
Your Access to Information
If you have an account with us, you may review and correct the information accessible to you under the settings for your account on our Sites or by calling 212-347-3210.
You may elect not to receive promotional correspondence from us. If you have an account with us, you may make this request under the settings for your account by indicating which correspondence you would like to receive. You can also send an email to hello@learneduco.com indicating whether: (i) you would like to opt out of receiving all email promotional correspondence from us in general, (ii) you would only like to opt out of certain of our newsletters or correspondence (and if so, which ones), or (iii) you would like to opt out of receiving SMS or text messages. You may also opt out of our promotional emails by clicking on the opt-out link within the emails you receive.
Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications with us.
When you contribute to a public area or feature of our Sites, the information you submit will be made available to the general public. Therefore, we recommend that you do not submit any sensitive information to such areas, including your full name, home address, phone number, financial information, or any other information that would enable other users to locate or contact you.
When you are on our Sites, you may be able to visit or link to other sites not operated by us. We do not control such sites and are not responsible for their information practices. This Privacy Policy does not address the information practices of those other websites, and we encourage you to read the posted privacy policies of any sites you visit.
We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we collect. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.
The information in this section applies only to California consumers. Any terms defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act ("California Privacy Law"), have the same meaning when used in this section.
Personal Information (Including Sensitive Personal Information) We Collect
We may collect, and in the past 12 months have collected, the following categories of personal information
Identifiers (such as name, address, email address, cookies, IP address, device identifiers, date of birth, and student ID number)
Categories of personal information listed in the California Customer Records statute (such as phone number, credit card number, and education)
Characteristics of protected classifications under California or federal law (such as military or veteran status and race)
Commercial information (such as purchase or enrollment history)
Internet or other electronic network activity information (such as interaction with our Sites)
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (such as test scores, GPA, course enrollments, and transcripts)
Audio, electronic, visual, or similar information (such as recorded voice, recorded video, and photos)
Professional or employment-related information (such as employer information and job title)
Inferences drawn from other categories of personal information to create a profile reflecting the consumer's preferences, characteristics, behavior, attitudes, abilities, or aptitudes
Sensitive personal information:
Account log-in in combination with any required security or access code, password, or credentials allowing access to an account
Financial account, debit card, or credit card number in combination with any required security or access code
Racial or ethnic origin or citizenship or immigration status
Personal information of consumers that we have actual knowledge are less than 16 years of age
Sources from Which Personal Information Is Collected
We collect personal information from the categories of sources described in the "Information We Collect" section above, including consumers, third parties with whom we have a business relationship, other users who refer you to us, publicly and commercially available sources, browsers and tracking technologies, and our service providers and other vendors.
Purposes for Which Personal Information Is Collected or Used
We may collect or use personal information for the purposes listed in the "How We Use Information" section above. We do not use sensitive personal information for purposes other than to perform the Services or provide the goods reasonably expected by an average consumer who requests those goods or services.
Personal Information Sold or Shared
We may be deemed to "sell" or "share" personal information (but not sensitive personal information) to or with third parties who provide online advertising services to us for the purpose of cross-context behavioral advertising, and may be deemed to have sold or shared personal information of California consumers in the preceding 12 months for that purpose. We do not knowingly sell or share the personal information of minors under 16 years of age, and we do not have a process for those under 16 to opt in to such sharing.
Personal Information Disclosed for a Business Purpose
In the preceding 12 months, we have disclosed to third parties for a business purpose all of the categories of personal information listed above. We disclose personal information to organizations that arrange for consumers' participation in our Services, to third parties whose products or services we resell, and to our contractors, service providers, and other vendors who help deliver our Services and operate our business.
Your Right to Know
You have the right to request that we disclose information about our collection, use, disclosure, sale, and sharing of your personal information. Upon verification of your request, and subject to exceptions provided under the California Privacy Law, we will disclose:
The categories of personal information we collected about you.
The categories of sources from which we collected your personal information.
The business or commercial purpose for collecting, selling, or sharing your personal information.
The categories of third parties to whom we disclosed your personal information.
The specific pieces of personal information we collected about you.
If we sold or shared your personal information, the categories of personal information sold or shared and the categories of recipients.
If we disclosed your personal information for a business purpose, the categories of personal information disclosed and the categories of recipients.
Your Right to Deletion
You have the right to request that we delete your personal information that we have collected, subject to exceptions provided under the California Privacy Law.
Your Right to Correct Inaccurate Personal Information
You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of processing.
Your Right to Opt Out of the Sale and Sharing of Personal Information
You have the right to opt out of the sale of your personal information and the sharing of your personal information for cross-context behavioral advertising. You may exercise this right by contacting us at hello@learneduco.com or 212-347-3210.
In your browser settings or through a browser extension, you can also have your browser send an opt-out preference signal. We will process the signal at the browser level so that when we detect the signal from your browser, we will opt you out of the sale and sharing of your personal information so long as you are using the same browser with the opt-out preference signal enabled.
Submitting Requests
To exercise your right to know, right to deletion, right to correction, or right to opt out, please submit a request to us by:
Calling us at 212-347-3210; or
Emailing us at hello@learneduco.com
You may only make a verifiable consumer request to know twice within a 12-month period. You may authorize another person to act as your agent to submit requests on your behalf. You may also submit requests on behalf of your minor child.
Verification
We will verify your identity before fulfilling your request to know, delete, or correct. If you have an account with us, we will ask you to enter your username and password through a link we provide. If you do not have an account, we will ask you to provide data points that we have about you to verify your identity. If you authorize another person to act as your agent, we will ask the agent to provide written authorization signed by you, confirm with you that you provided the authorization, and verify your identity. If you submit a request on behalf of a minor child, we will ask you to provide information that allows us to determine that you are the parent or guardian of the child.
Our Response
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we reasonably require more time (up to 45 additional days), we will inform you of the reason in writing within 45 days of receipt. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive or manifestly unfounded.
Your Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising the rights conferred by the California Privacy Law.
How Long We Retain Personal Information
The length of time we retain each category of personal information is determined by various criteria, including maintaining our ability to provide our Services and honor contractual obligations, address complaints and defend against claims, maintain records for audit purposes or as required by law, the type and duration of your relationship with us, and the retention policies of our service providers.
Processing of De-identified Data
We commit to maintaining and using de-identified data without attempting to re-identify the data.
If you are a resident of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have additional rights under your state's privacy laws, subject to exceptions and limitations set forth in those laws. These rights may include:
The right to confirm whether we are processing your personal data and to access such personal data.
The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of processing.
The right to delete personal data provided by or obtained about you.
The right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
The right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of your personal data, and (where applicable) profiling in furtherance of decisions that produce legal or similarly significant effects.
Where applicable, the right to obtain a list of the categories of third parties to which we have disclosed personal data.
We process the following categories of personal data:
Name and date of birth
Contact information (such as address, email address, and phone number)
Online identifiers (such as cookies, IP address, and device ID)
Identification numbers (such as student ID number)
Education and school information (such as test scores, course enrollments, graduation year, GPA, and transcripts)
Payment information (such as credit card number)
Commercial information (such as purchase or enrollment history)
Online activity (such as interaction with our Sites)
Audio or visual information (such as recorded voice, recorded video, and photos)
Professional or employment-related information (such as employer information, job title, and military or veteran status)
Sensitive data (such as personal data revealing racial or ethnic origin, citizenship or immigration status, and personal data of children under the age of 13)
We process personal data for targeted advertising. Depending on your state of residence, such processing may be deemed a "sale" of personal data. You may opt out of such processing by contacting us as described below.
In your browser settings or through a browser extension, you can also have your browser send an opt-out preference signal. We will process the signal at the browser level so that when we detect the signal from your browser, we will opt you out of the processing of your personal data for targeted advertising so long as you are using the same browser with the opt-out preference signal enabled.
To exercise any of the rights described above, or to revoke consent you previously provided to the processing of your sensitive data, please submit a request to us by:
Calling us at 212-347-3210; or
Emailing us at hello@learneduco.com
We will provide information in response to your request free of charge once during any 12-month period (or twice, where required by applicable state law). If your requests are manifestly unfounded, excessive, technically infeasible, or repetitive, we may charge a reasonable fee or decline to act on the request.
A parent or legal guardian of a child under the age of 13 may submit requests on behalf of the child. In certain states, a guardian or conservator may submit requests on behalf of another person subject to guardianship or conservatorship. You may authorize another person, acting on your behalf, to opt out of the processing of your personal data for purposes of targeted advertising and the sale of your personal data.
We will verify your identity before fulfilling your request (other than an opt-out request). We endeavor to respond to a request within 45 days of receipt. If we reasonably require more time (up to 45 additional days, or longer where permitted by state law), we will inform you of the extension together with the reasons for the delay.
If we decline to take action on your request, you may appeal our decision by emailing us at hello@learneduco.com with the subject line "Privacy Request Appeal." Within 45 to 60 days of receipt of your appeal (depending on applicable state law), we will inform you of any action taken or not taken in response, together with a written explanation. If you have concerns about the results of the appeal, you may contact the attorney general of your state.
We commit to maintaining and using de-identified data without attempting to re-identify the data.
Nevada residents have the right to opt out of the sale of certain personal information to third parties who intend to license or sell that information. We do not currently sell personal information as defined under Nevada law, but if you would like to submit a request regarding this right, please contact us at hello@learneduco.com.
Our Sites and Services are intended for users located in the United States. If you access our Sites from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where our servers are located and our central database is operated. By using our Services or providing us with any information, you consent to this transfer.
We reserve the right to modify this Privacy Policy at any time. Any such modifications will be effective upon posting to our Sites, with the updated effective date indicated at the top of this Privacy Policy. Your continued use of our Sites or Services following the posting of changes constitutes your acceptance of such changes.
If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at:
Educo LLC
1178 Broadway, 3rd Floor, #594
New York, NY 10001
Email: hello@learneduco.com
Phone: +1 (212) 347-3210
