Privacy Policy

1. Overview

Thank you for your interest in Attainment Holdco, LLC, a Delaware public benefit limited liability company, d/b/a InStride (“InStride”). This Privacy Policy describes: (i) how we handle Personal Information and Non-Personal Information you provide us when you access or use our Site; and (ii) options you have with respect to our use of your Personal Information and Non-Personal Information (collectively, “Information”).

BY ACCESSING OR USING OUR SITE OR SUBMITTING INFORMATION TO US VIA OUR SITE, YOU CONSENT TO OUR USE OF YOUR INFORMATION AS DESCRIBED HEREIN, AND AGREE TO COMPLY WITH OUR WEBSITE TERMS OF USE WHICH CAN BE ACCESSED AT [hyperlink]. Terms which are capitalized but not defined in this Privacy Policy have the meanings assigned in the Website Terms of Use.

2. California Privacy Act

California Shine the Light Act. 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.

3. Personal Information We Collect

3.1 Personal Information.“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. The following are categories (with non-exhaustive examples) of Personal Information we may collect about you:

(a) Individual Identifiers. Real name, postal address, online identifier, Internet Protocol address, email address, or other similar identifiers.

(b) Commercial Information. Records of products considered.

(c) Network Information. Information regarding your interaction with our Site or advertisements.

(d) Geolocation Data.

(e) Professional / Employment Information. Work contact information; organization, industry.

(f) Education Information. Previous educational agency or institution attended, dates of attendance, degrees and awards received, future educational agency or institution information.

(g) Inferences from the Foregoing. Profile reflecting preferences, characteristics.

4. Non-Personal Information and Aggregate Data

We may also collect and process Non-Personal Information or Aggregate Data as described below. We may use or share Non-Personal Information or Aggregate Data with third parties for industry analysis, demographic profiling, or other purposes

4.1 Non-Personal Information.“Non-Personal Information” means data that is not related to you and does not, by itself, permit the identification of particular persons or households. To the extent we deidentify data, or collect information from you that is not directly or indirectly associated with a particular consumer or household, we consider that information to be “Non-Personal Information.”

4.2 Aggregate Data. After removing any personally identifying information from within the set of Personal Information we collect from you, we may combine that information with information we collect from other individuals as well as other Non-Personal Information (collectively, “Aggregate Data”) in order to improve the quality and value of our services.

5. Personal Information Sources

We may collect Personal Information about you from a number of sources. Below are the categories of sources from which we receive this information:

5.1 Personal Information you voluntarily provide to us. We receive your Personal Information when you provide it to us. For instance, when you submit information to us via a fillable web form you may provide information such as your name and e-mail address. You may decide to provide other Personal Information such as educational or professional information via fillable web form. You may also provide us Personal Information when you contact us by telephone, postal mail, social media, or messaging (e.g., e-mail, SMS, MMS, or similar technologies). You will know what Personal Information you submit because you affirmatively provide such information to us by filling out a form, sending an e-mail, or otherwise communicating information to us.

5.2 Automatically Collected Information. By its nature, our Site also automatically collects some Personal Information about you. In order for you to view or interact with the Site, we receive Individual Identifiers like your IP address and Network Information like date and time of pages visited. The Site may collect this Personal Information even if you are not logged in. We collect some Personal Information automatically using Cookies or other tracking technologies as described in our Cookie Policy.

5.3 Information acquired elsewhere. We may also acquire your Information offline or through sources unrelated to your use of our Site. For example, we may receive information about you from your employer or university if you utilize our Services. We may merge or co-mingle that Information with your Personal Information and other data collected on or through the Site.

6. Purposes for Which We Collect Personal Information

Below are the purposes for which we collect Personal Information, with illustrative, non-exhaustive, examples of how we use the Personal Information to fulfill each purpose:

Information CategoryBusiness or Commercial Purpose for Collection
Individual Identifiers

·    To contact you with relation to current and future Services

·    To provide you with information you request

·    To analyze and improve our Site and Services

·    To maintain your customer profile

Commercial Information

·    To contact you with relation to current and future Services

·    To provide you with information you request

·    To analyze and improve our Site and Services

·    To maintain your customer profile

Network Information

·    To contact you with relation to current and future Services

·    To provide you with information you request

·    To analyze and improve our Site and Services

·    To serve you relevant advertisements on and off our Site

·    To maintain your customer profile

Geolocation Data

·    To contact you with relation to current and future Services

·    To provide you with information you request

·    To analyze and improve our Site and Services

·    To maintain your customer profile

Employment/ Professional Information

·    To contact you with relation to current and future Services

·    To provide you with information you request

·    To analyze and improve our Site and Services

·    To maintain your customer profile

Inferences from the Foregoing

·    To contact you with relation to current and future Services

·    To provide you with information you request

·    To analyze and improve our Site and Services

·    To serve you relevant advertisements on and off our Site

·    To maintain your customer profile

7. Limited Use

We will use your Personal Information only for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider de-identification, aggregation, and other forms of anonymization 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.

If you wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact us via the information specified in the Contact section below.

PLEASE NOTE WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.

8. How We Share Personal Information

We disclose and share your Personal Information as described below and elsewhere in this Privacy Policy.

8.1 Universities and Employers. We may share your Personal Information with participating employers and universities in order to provide you with Services or educational opportunities for which you are eligible.

8.2 Parent and Subsidiary Companies. We may share some or all of your Personal Information with companies with shared ownership in order to provide you with Services or potential educational opportunities, notify you of marketing offers, or any purpose set out in Section 5 above.

8.3 Service Providers. We may from time to time use business partners, suppliers, and sub-contractors (“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, or any purpose set out in Section 5 above. These Service Providers 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.

8.4 Third Parties. We do not share Personal Information with third parties for their direct marketing purposes without your permission.

8.5 Compliance with Laws. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose your Personal Information to government or law enforcement officials or private parties in response to lawful requests when we believe disclosure or sharing is necessary to comply with any legal obligation, enforce or apply our terms and conditions, respond to claims and legal process, protect our Service, Members, our rights and/or the safety of the public or any person, or prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).

8.6 Sale or Transfer of Business or Assets. 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 acquires our business, or assets, that company will possess the Personal Information maintained by us and may continue to use your Personal Information for compatible purposes. Any such company will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

8.7 Other Legitimate Business Purposes. We may also disclose your Personal 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 via e-mail and/or a prominent notice on our Site.

9. COOKIES AND OTHER TRACKING TECHNOLOGIES

The Site uses Cookies and other tracking technologies. Please review our Cookie Policy for more information on what Cookies are, how the Site uses tracking technologies, and choices you have with respect to such tracking methods.

10. Your Choices

You have the following choices with respect to the Personal Information we hold about you. To protect your privacy and security, we may take reasonable steps to verify your identity before granting requests to access, alter, or delete your Personal Information. Your options with respect to Personal Information are as follows:

(a) Access or Correct your Personal Information. You can request access to or correction of your Personal Information by phone, e-mail, or in writing using the information provided in the Contact section below.

(b) Deleting Your Information. You may ask us to delete your Personal Information at any time by phone, e-mail, or in writing using the information provided in the Contact section below. Please note we may maintain some portions of your Personal Information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements. We will delete or anonymize all your Personal Information as described in this subsection (b) within 30 days of your request for deletion.

(c) Revocation Of Consent. The Site relies on the processing of Personal Information you provide. If you revoke your consent for the processing of Personal Information, in accordance with this Privacy Policy, then you must discontinue all use of Site and notify us of such revocation using the information in the Contact section below. We may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity.

11. Opting Out

You can make the following choices regarding your Personal Information:

(a) Promotional E-mails. 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 Site or Services, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or sending a request to the e-mail address in the Contact section below. If you decide not to receive promotional e-mails, we may still send you service related communications, and our applications may deliver notifications directly to you through Services.

(b) Behavioral Advertising. Services use behavioral advertising. This means that a third party may use technology (e.g., a Cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our Site, or on other websites not operated by us. If you wish to limit third parties’ collection of information about your use of our Site, you can opt-out of such 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 OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

(i) Analytics. Many analytics providers allow end-users to opt out of the retention of their information, including our third-party analytics providers. Please note that typically, unless you create an account with the analytics provider, your choice to opt out applies only to the device from which you make the request, because the providers use Cookies on that device to recognize your choice. If you get a new device, install a new web browser, update your browser, or otherwise erase/alter your browser cookie files you may clear the opt-out cookie.

You may 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

(ii) Cookies. You may disable, or delete cookies in your web browser as described in our Cookie Policy, but doing so may impact the usability of the Site. To block cookies, you can also browse our Site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “In Private” for Internet Explorer, “Private Browsing” in Firefox and Safari).

12. International Transfers of Information

International Data Transfer. Your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding Personal Information may be less stringent than the laws in your country. Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach or other use that is prohibited in your country. By submitting your Personal Information, you agree to this transfer, storage and/or processing, including all associated risks.

13. Exercising Your Privacy Rights

When exercising the rights or options described in this policy, the following guidelines apply:

13.1 No fee usually required. You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

13.2 What we may need from you. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose Personal Information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

13.3 Time to respond. We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

13.4 No discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.

14. Do Not Track

Do Not Track is a privacy preference users may be able to set in their web browsers. When a user turns on a Do Not Track signal, their browser typically sends a message to websites requesting it not track the user. At this time, we do not recognize or respond to Do Not Track browser settings or signals and we will still receive information. As a result, we may still collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

It is possible that some or all of our third-party advertising partners or members of their affiliate network may participate in consumer opt-out programs. To learn more about internet-based advertising and consumer opt-out programs go to http://aboutads.info/choices or http://www.networkadvertising.org/choices.

15. Information Security

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.

We employ physical, procedural, and technological measures designed to protect your Personal Information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If you have questions about the security of your Personal Information, contact us at the e-mail or regular mail address specified in the Contact section below.

16. Retention of Personal Information

We will retain your Personal 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 for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and the applicable legal requirements.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, in our sole discretion. When we do so, we will post the new Privacy Policy on our Site. You should consult this Privacy Policy 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 Services. This Privacy Policy was last updated on the “Last Revised” date herein.

18. Contact Us

If there are any questions regarding this Privacy Policy, you may contact us at:

448 S Hill St 2nd Floor, Los Angeles CA 90013

(310) 954-1578

privacy@instride.com

Last Revised: APRIL 1, 2019.

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