Legal

California Privacy Notice

Important Information for California Residents

This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
    • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
  • Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Deletion. You can ask us to delete the Personal Information that we have collected from you.
  • Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
  • Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

How to exercise your rights

You may exercise your California privacy rights described above as follows:

Right to information, access and deletion

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Categories of Personal Information We Process

The charts below summarize how we collect, use and share Personal Information by reference to the statutory categories specified in the CCPA, and describe our practices during the 12 months preceding the effective date of this Privacy Policy. Categories in the chart refer to the categories described above in the general section of this Privacy Policy.

Statutory category of personal information (PI) Source of the PI Purpose for collection Categories of third parties to whom we “disclose” the PI for a business purpose Categories of third parties to whom we “sell” the PI
Education Information Customer Operations Service-related third parties; professional advisors None
Geolocation Data Customer Operations Service-related third parties; professional advisors None
Identifiers Customer Operations Service-related third parties; professional advisors None
Inferences Customer Operations Service-related third parties; professional advisors None
Online Identifiers Customer Operations Service-related third parties; professional advisors None
Professional or Employment Information Customer Operations Service-related third parties; professional advisors None
Protected Classification Characteristics Customer Operations Service-related third parties; professional advisors None

Glossary

Statutory category Definition (categories may overlap) What we collect
Education Information Personal information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates. Name of school(s) attended
Dates of attendance
Degree(s) earned
Certification(s) earned
Geolocation Data Precise location, e.g., derived from GPS coordinates or telemetry data. —
Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Name
Alias
Postal address
Telephone number
Email address
Inferences The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. May be derived from your:
Device data
Online activity data
Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device. Device data
Identity data
Professional or Employment Information This term is not defined in the CCPA, but likely includes any information relating to a person’s current, past or prospective employment or professional experience (e.g., job history, performance evaluations). Current and past job history
Job Title
Protected Classification Characteristics Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Sex/Gender
Age (may be inferred from birth date)