This California Privacy Notice (“Notice”) applies to InStride and is effective as of the Last Revised date of our Privacy Policy.  For California consumers, this Notice supplements and supersedes the practices we have adopted for our web site as described in our Privacy Policy, to describe our company’s collection, use, and disclosure of personal information. All defined terms within the California Consumer Privacy Act, including those defined in Cal. Civ. Code § 1798.140, apply for the purposes of interpreting this Notice. Terms which are capitalized but not defined in this Notice have the meanings assigned in the Privacy Policy.

BY ACCESSING OR USING OUR SITE OR SUBMITTING INFORMATION TO US, OR CHOOSING TO RECEIVE OR CONTINUE TO RECEIVE OUR SERVICES AFTER BEING PROVIDED THIS NOTICE, YOU UNDERSTAND AND CONSENT TO OUR USE OF YOUR INFORMATION AS DESCRIBED HEREIN, AND AGREE TO COMPLY WITH OUR WEBSITE PRIVACY POLICY AND TERMS OF USE.

As a California consumer, you have the right to request that we disclose what personal information about you we collect, use, disclose, and sell. More specifically, you have rights to the following without charge:

Disclosure of Personal Information We Collect About You

You have the right to know, upon submission of a verifiable request, the categories of personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, if any, and the specific pieces of personal information we have collected about you.

We will not retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; not reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; and reserve our right not to provide personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold or Disclosed for a Business Purpose

In connection with personal information we may sell or disclose for a business purpose, if any, you have the right to know the categories of personal information about you that we sold and the categories of third parties to whom we sold the personal information, and the categories of personal information that we disclosed about you for a business purpose, and the categories of third parties to whom we disclosed personal information for a business purpose.

Deletion of Personal Information

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your personal information from our records, and to have us direct our service providers delete your personal information from their records.

We are not required to, and reserve our right not to, delete your personal information it if is necessary to complete the transaction for which the personal information was collected or reasonably anticipated within the context of our ongoing business relationship with you, provide a good or service requested by you, or otherwise perform a contract between you and us; detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity; debug, identify, or repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act; enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us; comply with an existing legal obligation; and otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Your Right to Opt-out of the Sale of Personal Information

A “sale” under California law is defined as any transfer of personal information for value. Because personal information is valuable to many businesses, many commonplace transfers are considered to be sales under the law. You have the right to opt-out of the sale of your personal information. We do not sell personal information other than website analytics data.

If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information.

To opt-out of the sale of your personal information, click on the Do Not Sell My Personal Information link at the bottom of any page on our website, or click Do Not Sell My Information.

Children’s Personal Information

We do not knowingly collect personal information from individuals under 18 years of age, and do not sell the personal information of minors under 16 years of age without affirmative authorization. Our website is available only to individuals and entities that can form legally binding contracts under applicable law. You warrant that you are eighteen (18) years of age or older to use our website. If you do not qualify, you may not use our website. If you a parent or legal guardian, please do not to allow your children to submit personal information to us without your authorization.

Freedom from Discrimination

You have the right to not be discriminated against by us if you exercise any of your rights under the California Consumer Privacy Act. This means we cannot do any of the following on the basis of your exercise of these rights: deny goods or services to you; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

In most cases, we collect personal information directly from you. We also collect information from the following additional categories of sources:

In most cases, you will know when we collect personal information from you as you will actively provide it to us for a stated purpose. However, below is a description of additional types of personal information we collect in certain circumstances:

Program Participants: We collect personal information about you when you apply to or participate in an educational program through one of our corporate partners. This information may include advertisement tracking information, areas of interest, billing information, client ID, corporate ID, date of birth, email, employee ID, employer, fee amounts, mobile phone number, name, phone number, program ID, scholarship amounts, student ID, student progress reports, tuition cost, university ID, and other information you may share with us or may be required to provide you services.

Contact forms: If you submit information to us through forms made available to you on our website or otherwise by our firm, we may collect personal information from you including your name, address, phone, email, employer, and any message content you may choose to provide.

Events: We collect personal information about you if you register for an event we host or sponsor. This personal information may include your name, address, title, company, phone number, and email address, as well as specific information relevant to the event for which you register.

Communications: If you choose to contact us for any purpose, we will collect your name, contact details, and the date and time of your contact along with the content of your message. You may also choose to receive news, updates, or client alerts from us. When you sign up, we may collect your name, company, email address, and areas of interest.

Automatically Collected Personal Information: By its nature, our website also automatically collects some personal information about you. In order for you to view or interact with our website, we receive individual identifiers like your IP address and some network information like date and time of pages visited. We collect some personal information automatically using cookies or other tracking technologies, described in more detail in the cookies section below. The personal information automatically collected may be collected by or on behalf of third parties who provide us inferences or reporting based on analysis of such personal information.

Other sources: We may receive personal information about you from other sources, including third parties that help us update, expand, and analyze our records, identify new customers, or prevent or detect fraud. We may also receive information about you from social media platforms, for example when you interact with us on those platforms or access our social media content. Information we receive through such platforms is governed by the privacy settings, policies, and/or procedures of the platform, and we encourage you to review them.

Please be aware that some links on our website or that we otherwise provide to you may direct you to websites operated by third parties. Information submitted on those websites is provided to the owner(s) of those websites, not us, and subject to the privacy policies of those sites, and not this policy.

We collect personal information in order to facilitate the enrollment and participation of our corporate partners’ employees in educational programs provided by our educational partners.

In addition to those purposes and the purposes described in our Privacy Policy, we also collect your personal information for the purposes of detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; debugging to identify and repair errors that impair existing intended functionality; short-term, transient use, where the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter your experience outside the current interaction; performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying client information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on our behalf; and undertaking activities to verify or maintain the quality or safety of services that are owned or controlled by us, and to improve, upgrade, or enhance those services.

Please note that we may process your personal information without your knowledge or consent, as required or permitted by law. We consider de-identification and aggregation of personal information to be compatible with the purposes listed above and in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information.

We generally disclose personal information with our educational partners and corporate partners as necessary to provide educational programs to our corporate partners’ employees. We also share personal information among our service providers and other third parties as described below:

Corporate Partners

In order to provide access to educational programs for the employees of our corporate partners, it is necessary for us to provide our corporate partners personal information about their eligible and participating employees.  This information may include billing information, employer information, fee amounts, student name, employee name, program ID, scholarship amounts, student ID numbers, student progress reports, tuition amounts, or other information sought by our corporate partners to meet their program goals.

Educational Partners

In order to provide access to educational programs for the employees of our corporate partners, it is also necessary for us to provide our educational partners personal information about eligible and participating employees of our corporate partners.  This information may include academic interests, client ID, corporate ID, date of birth, email, employee ID, advertisement tracking information, name, phone number, program ID, university ID, or other information sought by our educational partners to provide educational programs. 

Service Providers

We may from time to time use business partners, suppliers, and sub-contractors to assist us with the provision of services to you (for example, without limitation, website hosting, web analytics, maintenance services, database management, billing, payment processing, fraud protection, credit risk reduction, marketing, product research, or improvement of services). These entities have access to your personal information only to perform the respective tasks assigned to them on our behalf, and are obligated not to disclose or use it for any other purpose. For the purposes of this Notice, these are our “service providers.”

Third Parties

We may share personal information with the following categories of third parties: advertising networks, data analytics providers, government entities, internet service providers, operating systems and platforms, and social networks. For the purposes of this Statement, “third party” or “third parties” means third party as defined by the California Consumer Privacy Act, and includes parties that may sell, retain, use, or disclose personal information for certain purposes beyond the limited scope of our contract or direct business relationship with such entities. 

Other Reasons for Which We Will Share Personal Information

We may cooperate with government and law enforcement officials as required by applicable law and/or in the course of legal proceedings. If you give us permission, or if we believe doing so is required or appropriate, we may disclose personal information to government or law enforcement officials or private parties in response to lawful requests, to comply with a legal obligation, to enforce or apply our terms and conditions, to protect our services, our rights, and/or the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).

We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company or individual acquires our business, or assets, that company or individual will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Notice.

Categories of Personal Information Collected, Disclosed, and Sold.

Unless otherwise specified, to exercise any of your rights described in this Notice, please complete a data subject request form available at our CCPA Request Form or call us toll-free at (888) 374-1578.

In order to verify your request, you will need to provide us with enough information to identify you, verify your identity and address, and a description of what right you wish to exercise along with any information to which your requests relates.

You may also designate an authorized agent to make a request under the California Consumer Privacy Act on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require you verify your own identity with us directly.

We reserve our right not to make a data access or portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. You will not have to pay a fee to exercise your rights described herein. However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive. You may only make a request to know or receive personal information twice within a 12-month period.

We may update this Notice from time to time, in our sole discretion. When we do so, we will post the new Notice on our website. You should consult this Notice regularly for any changes. Continued use of services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.

For consumers who require this Notice in an alternative formation, it is provided on the InStride website in a format that is compatible with text-to-speech technologies.  If you require additional formats or assistance, please contact us at the address, email, or toll-free phone number below.

If you have questions regarding this Notice or our treatment of your personal information, you may contact us at the following:

700 S Flower St., Suite 1800, Los Angeles, CA 90017

(888) 374-1578

privacy@instride.com

Last Revised: December 31, 2019.

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.

To request a copy of the information disclosure provided by us pursuant to Section 1798.83 of the California Civil Code, your request must include “California Privacy Rights Request” in the subject or first line of the request and include your name, street address, city, state, and zip code. You must send your request to us via e-mail or mailing address in the Contact Us section below.

Please note that under this law we are not required to respond to your request more than once per calendar year, nor are we required to respond to any request that is not sent to the e-mail or mailing address provided.

Copyright © 2019 Attainment Holdco, LLC, a Delaware public benefit limited liability company. All rights reserved