Last Updated: 06/22/2021
1. Information We Collect
Information we collect from you, your employer, or your university. We collect the following types of information from these sources:
- Contact information, such as your name, email address, phone number, and physical address.
- Log-in information, such as the username and password you use to access the Services.
- Demographic information, including your age and areas of interest.
- Commercial information, such as records of products you have purchased or considered purchasing, and associated payment information.
- Professional/Employment information, such as your work contact information and employee identifiers, your role, the name of your employer, and the industry in which you work.
- Education information, such as information about previous educational agencies or institutions attended, dates of attendance, degrees or certificates received, enrollment and completion information regarding the courses you complete with our academic partners, progress reports, tuition and fee amounts, and university identifiers.
- User-generated content and messages, such as information you post to the Services or messages you send us when requesting customer support.
Information we collect from your computer or device. As you use the Services, we and our service providers (who are third parties that perform services on our behalf) may automatically collect information about the computer or device you use to access the Services. This information includes your IP address, browser type, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Offerings, error logs, and other similar information. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).
Information we collect from others. We may receive 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.
2. How We Use Your Information
We use the information collected from and about you to:
- Provide and offer the Services to you
- Respond to your requests for information and provide you with more effective and efficient customer service
- Contact you in connection with your use of the Services and future Services
- Analyze use of the Services to better understand how users are interacting with the Services, improve the Services, and create new products and services
- Customize the content you see on the Services
- Secure the Services and resolve technical issues
- Comply with any procedures, laws, and regulations which apply to use where it is necessary for our legitimate interests or the legitimate interests of others
- Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected through our Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, partners, and sponsors.
Employer/University Information. Please note that if we have collected your information from your employer or university, our use of certain of your information will be governed by the relevant agreement we have with your employer or university. With respect to the information provided by your employer or university that we are processing on their behalf and on their instructions, your employer or the university is the data controller of your information and InStride is either a separate data controller or a data processor, depending on the contractual relationship between us and them. If you have any questions about our respective roles, you can contact us using the information provided below in the “Contact Us” section.
3. Legal Bases for Processing Your Information
- Where we need to process your information to provide the Services to you pursuant to the relevant contact between us
- Where processing is necessary for our legitimate interests (or those of others) and your interests and fundamental rights do not override those interests
- Where we need to comply with an applicable legal obligation
- Where we have your consent to process your information in a certain way
4. Online Analytics and Advertising
You can learn more about opting-out of analytics from our third-party providers by visiting their respective opt out pages including the following:
Google Analytics: https://tools.google.com/dlpage/gaoptout
If you wish to limit third parties’ collection of information about your use of our Services, and your use of other websites and services, you can opt-out at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. Please note that using these opt out options does not mean that you will not receive advertising while using the Services or while you are browsing the web. It will, however, exclude you from seeing interest-based tailored advertising conducted through participating advertising networks and providers pursuant to their policies. We are not responsible for maintaining these opt out choices or for the advertising activities of third parties.
5. How We Share Your Information
Please note that we do not share your information with third parties for their direct marketing purposes without your permission. We share your information in the following ways:
- Your Employer(s) as our Corporate Partner(s). To provide access to educational programs for the employees of our corporate partners, it is necessary for us to provide our corporate partners with information about their eligible and participating employees regarding applicable program fees, progress reports, and completion information.
- Your University(ies) as our Academic Partner(s). To provide access to educational programs for the employees of our corporate partners, it is also necessary for us to provide our academic partners with information about eligible and participating employees of our corporate partners to facilitate enrollment.
- Our Affiliates. We may share your information with companies under common ownership or control in order to provide you with Services to you.
- Service Providers. We work with third party service providers to assist us with the provision of Services to you (for example, without limitation, website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, improvement of Services). These service providers have access to your information to perform the respective tasks assigned to them on our behalf.
- Other Legitimate Business Purposes. We may also disclose your information when it may be necessary for other legitimate purposes as reasonably determined by us, in which case we will notify you of such use and/or seek your permission in accordance with our legal requirements.
6. Your Rights and Choices
Depending on your location and applicable local laws, you may have the following rights with respect to the information we process about you. To protect your privacy and security, we may take reasonable steps to verify your identity before granting such requests. Your rights may include the following:
- To access, in a machine-readable format, the information we process about you, including more information about the types of information we collect and how we use it and share it.
- To delete certain data that we process about you.
- To correct inaccurate information.
- To object to certain processing activities in which we engage based on our legitimate interests.
- To withdraw your consent to certain uses of your information, where the
reason why we processed that information was based on your consent.
You also have the right not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that all of these rights regarding your information are subject to certain exceptions. For example, we need certain information in order to provide our Services to you or to comply with our legal obligations. Please also note that the required response time for us to comply with your request may differ pursuant to applicable law.
If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us as explained in the “Contact Us” section below.
If certain of your information has been provided to us by your employer or university, and we are processing that data on your employer’s or university’s behalf pursuant to an agreement with them, we may need to direct you to your employer or university to request these rights. We will provide reasonable assistance to our customers and academic partners to give effect to consumer choices as appropriate and required by applicable laws.
Marketing Opt Out. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Services, as well as targeted offers from third parties. You can stop receiving these promotional e-mails by clicking the “unsubscribe” links in the e-mails or sending a request to the e-mail address in the “Contact Us” section below. Please note that it may take some time to process your request in accordance with our legal requirements. If you decide not to receive promotional e-mails, we may still send you service-related and other transactional communications.
SMS Opt Out. You may choose to subscribe to our SMS messaging service. Please review our SMS Terms and Conditions for more information, including how to unsubscribe.
7. Privacy Information for California Residents
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
How We Source, Use, and Disclose Information for Business Purposes
The CCPA provides certain rights if a company “sells” personal information, as such term is defined under the CCPA. We do not engage in activities that would be considered “sales” under the CCPA.
Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services, and that is why we provide the variety of opt-out mechanisms listed above in the “Online Analytics and Advertising” section. However, we do not currently recognize or respond to browser-initiated DNT signals.
8. Privacy Information for Nevada Residents
Certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the methods outlined below in the “Contact Information” section. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices
9. International Transfers of Information
Please note that our Services are provided from the United States, and will therefore involve the transfer and processing of your information in the United States. Also, in providing services to you, we may subcontract the processing of your data to, or otherwise share your data with, our affiliates and subsidiaries, trusted service providers, and trusted business partners (as discussed in the “How We Share Your Information” section above) in countries other than your country of residence, in accordance with applicable law. By providing us with your information, you acknowledge any such transfer, storage or use. When we have to transfer your data for these purposes, we will take appropriate measures to ensure such companies protect your information adequately in accordance with applicable law. Where required by applicable law, these measures may include signing standard contractual clauses. If applicable, you may make a complaint to the relevant data protection authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
10. Third Party Links and Features
11. Children’s Privacy
The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without legally valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
12. How We Protect Your Information
We employ a variety of physical, procedural, and technological measures designed to protect your information from unauthorized loss, misuse, access, disclosure, alteration, or destruction. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, although InStride regularly monitors our systems for possible attacks and vulnerabilities, we cannot guarantee its absolute security.
13. Retention of Information
We will retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information, whether we can achieve those purposes through other means, and the applicable legal requirements.
15. Contact Us
700 S Flower St. Suite 1800
Los Angeles, CA 90017
Copyright © 2022 Attainment HoldCo Attainment Holdco, LLC, a Delaware public benefit limited liability company. All rights reserved.