PRIVACY POLICY FOR
RESILIENT STUDENT, INC.
EFFECTIVE DATE: January 1, 2020Resilient Student, Inc. (“RS”, “we”, “us”, or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website www.resilientstudent.org (the “Site”), our locations, users of our services (“Services”) and how we use and disclose that information. By visiting the Site, or using our Services at our Site or our locations, you agree that your personal information will be handled as described in this Policy.
If you are a California resident, please see our California Privacy Notice below for information regarding our collection of personal information both through this Site and at our California locations.
This privacy policy describes the data collection practices of websites owned and operated by Resilient Student, Inc..com, including www.resilientstudent.org (“Site”), owned and operated by Resilient Student, Inc., Inc. This policy is meant to inform our Site visitors (“you,” “your”), of how we may collect, use, and disclose your information.
By accessing or using the Site, you agree to the terms of this Privacy Policy. If you do not agree to the terms of this statement, then please do not use our Site.
If you are located outside of the United States, you should know that the information you provide to us is being transmitted to us and processed in the United States, under this Privacy Policy and subject to applicable laws, which may not be as protective as the laws in your country.
Collection of Information
We collect information about you directly from you and from third parties, as well as automatically through your use of our Site.
Information We Collect Directly From You
You can contact us to obtain more information and consultation about the Services that we provide by filling out the form on our Site, and providing the following information: student name, parent name, parent phone, parent email, and zip code; however, you are not required to provide us with this information. Information regarding any student that is a minor must only be provided by the student’s parent and legal guardian.
If you visit or sign up for Services, we may collect the following information from you or your student:
Student name, student date of birth, parent name, parent phone, parent address, and parent email.
Credit card information for payment of fees for our Services.
Information on a student’s education, including grades, activities and other information that would be provided in connection with college applications (“Admissions Information”).
If you choose to schedule a consulting session, we may ask you to provide your first and last name, phone number, email address, institution name, job function, job level and other optional information so that we may respond appropriately to your request.
You may choose to provide us with your email address in order to receive updates regarding our products and services.
Events: If you choose to register for a Resilient Student, Inc. event, we may request your name, email address, phone number, institution name and job title.
Log Data Collection:
As part of the standard operation of the Site, we may automatically collect certain information from you, including but not limited to your browser type, operating system, IP address and the domain name from which you accessed the Site (“Log Data”). In addition, we may collect information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other click-stream data.
We use cookies to collect the information described above. A cookie is a small text file that may be stored on the hard drive of your computer or device. Most browsers have settings that allow you to delete cookies, to stop accepting cookies, or to prompt you before accepting a cookie. You are free to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Check the “Help,” “Tools,” or similar section of your browser to learn more about browser cookies, including how to manage or delete them, or visit allaboutcookies.org.
Pixel Tags. A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that we may place on our website or in an email to you, to tell us when you have displayed that page or opened that email. These help us measure the effectiveness of our e-mail campaigns, by telling us whether the messages have been received, opened or otherwise acted upon.
By using our Site, you agree to our use of these tracking technologies.
We use Google Analytics to assist us in collecting and understanding Log Data. For more information about Google Analytics, see the Google Privacy Policy.
Third-Party Tracking:
We do not serve advertising on our Site; however, when you use the Internet, parties both affiliated and not affiliated with us, such as advertising networks, web analytics companies and social networking platforms may collect information about your online activities over time and across this Site and other websites. This information may be used to provide advertisements for products and services that may interest you, and those companies may use cookies, clear GIFs and other tracking technologies. We do not track your activity over time and across different websites or online services. Nor do we honor “do not track” signals transmitted by web browsers.
For more information about third-party advertisers and for information about how to prevent them from using your information, visit the Network Advertising Initiative’s (NAI) consumer website at http://www.networkadvertising.org/choices or http://www.aboutads.info/choices/. If you do want to opt out using these tools, you need to opt out separately for each of your devices and for each web browser (such as Internet Explorer, Firefox or Safari) that you use on each device.
Information Use
We may share your information, including personal information, as follows:
Service Providers. We may disclose the information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf.
Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or are in negotiations with regard to any such transactions, we may transfer the information we have collected from you to the other company or legal entity.
In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
To Protect Others and Us. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of any applicable agreements with you or this Policy, or as evidence in litigation in which RS is involved.
Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
We do not sell or rent your information. We use and disclose your personal information only to respond to your requests, as described above and:
To provide you with customized content and marketing;
Reply to your sales inquiries and support requests;
Administer the Site, monitor its usage and diagnose problems with it;
Remember you when you return to the Site, so that you don’t have to re-submit information and preferences;
Analyze use of the Site and improve our content and services;
Determine roughly where you are located, so that we can deliver marketing to you, while you are on the Site, based on your location and therefore as relevant to you as possible;
To investigate a suspected violation of our Terms of Service, suspected fraud or other unlawful activity;
As may be required by law or by a court order, in which case we shall attempt to notify you and work with you to seek to limit the scope of the required disclosure;
To our third-party service providers to allow them to provide Site features on our behalf, such as maintenance services, email management, web analytics and improvement of our Website.
With your consent and as permissible under applicable laws and regulations.
Third Party Service Providers
We may share your information with trusted third party companies and individuals to facilitate delivery of our Site and to provide certain features on our behalf, such as data hosting, customer service, maintenance services, email management, database management, web analytics, review, processing of event registration, including hotel registrations, dietary preferences and accommodations, processing of job applications and improvement of our Site.
Our Use of Cookies and Other Tracking Mechanisms
We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-Party Links section.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others allow us to track your activities at our Site. There are two types of cookies: session and persistent cookies.
Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you while visiting or completing a form on the Site.
Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track information about user activity, and to display advertising both on our Site and on third-party sites.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Third-Party Analytics
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and our Services. We use these tools to help us improve our Site and Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.
Third-Party Links
Our Site may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
Email Opt Out
If you have provided us with your information in order to receive updates from us or to receive information about our products, sales inquires, support requests we may send you email marketing messages. You may opt-out of these messages at any time by clicking on the unsubscribe link that appears at the bottom of each message, or by contacting us at privacypolicy@Resilient Student, Inc.
Data Retention
We retain information you provide only for as long as is necessary to fulfill the purposes as described in this Privacy Policy, or as otherwise permissible by law.
Access
To review, correct, or request that we delete your personal information, please contact us by email at privacypolicy@Resilient Student, Inc.
Links
Our Site contains social network sharing widgets. You may log onto third party social networking websites via social network sharing widgets to share, comment or recommend blog posts. The social network sharing widgets may provide information to their associated social networks or third-parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking websites, you should read their privacy disclosures, to learn what information they collect, use, and share.
Our Site also contains links to social networking and other websites. If you click on such a link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
Site Security
Security of My Personal Information
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private.
What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic promotional or informational emails to you, such as when you sign up for our newsletter at the Site. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.
Children Under 13
Our Site is not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems. We have implemented commercially reasonable, industry standard physical, technical, and administrative safeguards to secure your personal information. However, the Internet is not entirely secure, and we are not responsible for security incidents not reasonably foreseeable or not reasonably within our control.
Nevada Residents
We do not sell the personal information of Nevada residents as that term is defined under Nevada Law (Section Chapter 603A of the Nevada Revised Statutes). However, if you are a Nevada resident and wish to opt-out of any such sale, please contact us at privacy@resilientstudent.org
California Privacy Notice
This California Privacy Notice supplements the Policy and contains the disclosures required under the California Consumer Privacy Act (“CCPA”). For individuals who are California residents, the CCPA requires certain disclosures about the categories of personal information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it.
Please note that for California residents, the term personal information means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household as defined in the CCPA. All other capitalized terms have the same meanings as given them in the Policy.
If you are a California resident who has provided personal information to RS, or a California resident that reasonably believes that RS collected or stores your personal information, you may exercise your rights under the CCPA and submit your requests in one of the following methods: (a) by submitting this online form; (b) by calling the following toll free number at 888-308-8123.
NOTE: we do not sell your personal information as that term is defined in the CCPA.
You have the following rights under the CCPA:
Right to know about personal information collected, disclosed or sold
California residents have the right to request that we disclose what categories of personal information that we collect, use, disclose or sell about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or selling personal information and the categories of third parties with whom the business shares personal information. You may also request the specific pieces of personal information that we have collected about you.
Right to request deletion of your personal information
You may also request that we delete any personal information that we have collected from you, provided that we may retain personal information as authorized under the CCPA, including, but not limited to, retaining personal information necessary to provide our Services, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug to identify and repair errors that impair our Site and Services, to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us, comply with a legal obligation or otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which your provided it.
In order to submit a request, we will need to verify your identity. We may request two or more data points of personal information and other proof of identification depending on the nature of the request and the personal information requested to verify your identity.
Please note that following your verified request, we will send you your personal information from the following email address: privacy@resilientstudent.org (Any response to your request, including any personal information may be sent as an encrypted file).
We will process and respond to your request within 45 days (in some cases, as is allowed under the CCPA, this process may be extended by an additional 45-90 days).
Please note that once you have submitted a request, we will send you a receipt, acknowledging your request, within 10 days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send an email to privacy@resilientstudent.org as an error may have occurred.
Please note, that regarding requests under the heading “Right to know about personal information collected, disclosed or sold” above, you may only make two such requests in a 12-month period, and the information provided need only cover the 12-month period prior to your request.
As a California resident, you also have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us at privacy@resilientstudent.org for more information if you wish to submit a request through an authorized agent.
We hereby inform you that if you exercise any of your rights under the CCPA, we may not deny you goods or services for that reason, or subject you to different prices than those paid by other consumers, unless provided otherwise under the CCPA, Federal, or State law.
Notice of Information We Collect
Pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of personal information that we collect through the Site and at our locations and the commercial or business purposes for which we collected that information over the past 12 months. All of the categories of personal information we collect about you (as detailed below) come from the following categories of sources:
You, including through your use of our Site and Services and on behalf of any students that you enroll for our Services
Automatically collected from you
Our affiliate companies
Third parties
In particular, we have collected the following categories of personal information from California consumers within the last twelve (12) months for the following purposes:
A. Identifiers. We collect identifiers, including parent name, email address, phone, address, student name, student date of birth, Testing Information, Tutoring Information, Usage Information, and Job Posting Information.
Purpose: We collect this information to provide the Site and Services; to review, process, and evaluate job applicants; for marketing and promotional purposes; to contact you in response to your inquiries; and for security and fraud prevention purposes.
B. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)). We collect information covered by this law, including parent name, email address, physical address, phone number, signature, credit card number, student name, student email, student phone, credit card information, Job Posting Information, Admissions Information, Tutoring Information, and Testing Information.
Purpose: We collect this information to provide the Site and Services; to process payment transactions; for security and fraud prevention purposes; to review, process and evaluate job applicants; and to comply with legal reporting requirements; and for security and fraud prevention purposes.
C. Protected Classification Characteristics under California or federal law. If you choose to voluntarily provide it, we collect information on your race/ethnicity in connection with our reporting requirements of Equal Employment Opportunity Commission.
Purpose: We collect this information from job applicants on a voluntary basis in connection with employment with RS to comply with federal reporting requirements.
D. Commercial information. We collect information relating to your transactions with us, such as the tutoring, testing or college counseling Services you might have used.
Purpose: We collect this information to process transactions with you, to provide the Site and Services, to evaluate, develop and improve the performance, features and functionalities of the Site’s features and the Services, and for marketing purposes such as to contact you about products and services that may be of interest to you and others.
E. Biometric Information. We do not collect this information.
F. Internet or other similar network activity. See the description of the Usage Information we collect in the Policy.
Purpose: We collect this information to provide the Site and Services, to evaluate, develop and improve the performance, features and functionalities of the Site’s features and the Services, and for marketing purposes such as identifying products and services that may be of interest to you based on your Usage Information.
G. Geolocation Data. We may collect IP addresses that may allow us to identify the location of a user of our Site or Services. We do not track a mobile phone location.
Purpose: We collect this information to provide the Site and Services, to evaluate, develop and improve the performance, features and functionalities of the Site’s features and the Services, and for marketing purposes (such as identifying RS Education centers that may be located near to you).
H. Audio, electronic, visual, thermal, olfactory, or similar information. We may record phone calls through our call center and may have security cameras at our education centers, which may collect visual information about you. In addition, with your permission, we may take photos of you and your students for marketing and other purposes.
Purpose: We use the recorded phone calls to respond your inquiries, provide our Services, improve our Services and for follow-up marketing. We use our security camera footage for security and fraud prevention purposes. We use photos of you and your students for marketing purposes.
I. Professional or employment-related information. We collect professional and employment-related information in connection with job applications. Please see the above for the Job Posting Information we may collect. We may also obtain a parent’s employer or occupation if they choose to provide it when registering for our Services.
Purpose: We collect the Job Posting Information to process job applications and in connection with an applicant’s employment at RS. We use parent employer information as background information to assist us in providing Services to students.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). We may collect school transcripts and education records that may be relevant to our tutoring and college counseling services.
Purpose: We collect this information in connection with providing tutoring and collecting counseling Services.
K. Inferences drawn from other personal information. We may build profiles for our students based on their Admissions Information, Testing Information and Tutoring Information.
Purpose: We use this information to provide the Services, including assisting students in improving test scores and advising on the college admission process. We may also use it to improve our Services and may use aggregate and de-identified data based on such inferences to market our Services.
Non-discrimination: We shall not discriminate or otherwise penalize anyone for exercising their rights under this Privacy Policy.
Categories of Personal Information we collect
Identifiers such as first and last name, phone number, email address, institution name, job function, job level
If you apply for an open position with Resilient Student, Inc., identifiers such as your first and last name, email address, phone number, mailing address, resume, cover letter and other applicable details to consider you as a candidate for employment.
Internet or other electronic network activity information regarding your interaction with our Site.
Categories of sources from which the Personal Information is collected
We collect the Personal Information directly from you
Business or commercial purpose for collecting or selling Personal Information
Notice of Disclosures of Personal Information for a Business Purpose
In the past twelve months, we disclosed personal information as described in the How We Share Your Personal Information section of the Policy, including to service providers that perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of RS. Such service providers are prohibited from retaining, using, or disclosing the personal information for any purpose other than for the specific purpose of performing the services for us.
Performing services in including maintaining our Site and providing customer service
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.
Sending you marketing information if you opt in to receive it.
Auditing related to a current interaction such as counting ad impressions to unique visitors and verifying positioning and quality
California Civil Code Section 1798.83, also known as the “Shine The Light” law, also permits California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to: privacy@resilientstudent.org.
We collect your Personal Information to provide the Services and for the following business purposes:
Specific pieces of Personal Information we have collected
First and last name, phone number, email address, institution name, job function, job level and other optional information so that we may respond appropriately to your request.
Email address if you have chosen to subscribe to updates regarding our products and services.
If you apply for an open position with Resilient Student, Inc., your full name, email address, phone number, mailing address, resume, cover letter and other applicable details to consider you as a candidate for employment.
Privacy Rights of Individuals outside the United States
This website is hosted and operated in the United States, and is not intended to target E.U. residents or other individuals outside the United States or to monitor activities outside the United States. If you use our Site from outside the United States, you consent to the transfer of your information to RS in the United States, which may provide less protection to your personal information than your jurisdiction of residence. If you access this site, this Policy will apply to personal information that RS collects, uses, and distributes. Should you have questions or concerns regarding your personal information please send an email to:privacy@resilientstudent.org.
Changes to this Privacy Policy
As we continue to develop our Site, we may change this Privacy Policy. The “last updated” date at the top of this policy indicates when it was last revised. Changes will become effective when posted. If you do not agree to changes to this Privacy Policy, you may not continue to use this Site.