Privacy Policy and Notice at Collection

EFFECTIVE DATE: May 12, 2026

This Privacy Policy and Notice at Collection (“Policy”),  describes how C2 Educational Systems, Inc. (“C2”, “we”, “us”, or “our”) collects, uses, and discloses personal information that we obtain about visitors to our website www.c2educate.com and to any other website, mobile application, or online service that links to or expressly incorporates this Privacy Policy (collectively, the “Site”), users of our online and on-site services (“Services”), job applicants and candidates for employment, and other individuals when we interact with them through other online and offline methods, and how we use and disclose that personal information.  By visiting the Site, using our Services at our Site or our physical locations, applying to work with us, or otherwise interacting with us, you agree that your personal information will be handled as described in this Policy.

This Policy does not address our processing of the personal information of our employees and independent contractors for human resources, employment, benefits administration, health and safety, and other similar business-related and legal compliance purposes.

Individuals with disabilities may access this Policy in an alternative format by contacting [email protected]. Certain terms used in this Privacy Policy have the meanings given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act and implementing regulations (collectively the “CCPA”).

How Do We Collect Your Personal Information?

We collect and receive, and during the 12-month period prior to the effective date of this Privacy Policy, we may have collected or received personal information about you or, if you are a parent or guardian of a student receiving our services, your student (“you”): (i) directly from you when you provide it to us or our affiliates, such as when you fill out a form on the Site; (ii) from third parties, such as our service providers and business partners; as well as (iii) automatically and indirectly from you through your use of our Site, including through logging and analytics tools, cookies, pixel tags, and other technologies on our Site. For more information about our use of cookies or similar technologies, please see the section titled Our Use of Cookies and Other Tracking Mechanisms, below.

What Personal Information Do We Process and Why Do We Process It?

Depending on your interactions with us, we may not have collected or processed each of these categories of personal information about you. However, we may collect, use, disclose, or otherwise process (and may have collected, used, disclosed, or otherwise processed in the 12-month period prior to the effective date of this Policy), the following categories of personal information for the following purposes:

A. Identifiers and contact information, such as name, nickname, email address, phone number, mailing address, date of birth, and other personal or online identifiers (like IP address and login credentials).

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)), such as name, physical characteristics or description, phone number, signature, financial information such as credit card information, driver’s license number, and medical information (for example, information you choose to provide in connection with accommodation requests).

Purpose: We collect this information to provide the Site and Services; to process payment transactions; to review, process and evaluate job applicants; to comply with legal reporting requirements; and for security and fraud prevention purposes.

C. Demographic and Protected Classification Characteristics, such as gender, sex, age (40+), religion, marital status, sexual orientation, disability status, medical conditions, citizenship, nationality, and veteran or military status, or if you choose to voluntarily provide 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 C2 to comply with federal reporting requirements.

D. Commercial information, such as records relating to your transactions with us, the tutoring, testing or college counseling Services you might have purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

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 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. Internet or other similar electronic network activity, such as information about your use of our Site or Services collected through cookies, web beacons, and other technologies, including your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site; and the referring URL, or the webpage that led you to our Site, and the following: access time, browser type, device ID, domain name, IP address, page views and referring URL.  We may combine this information with other information that we have collected about you, including, where applicable, your name, email address, and other personal information.

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 and the Services, in connection with our recruitment activities, and for marketing purposes such as identifying products and services that may be of interest to you based on your Usage Information.

F. Geolocation Data, such as time and physical location related to your use of our Site, Services, or online applicant systems, or physical access to an office 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 and the Services, in connection with our recruitment activities, and for marketing purposes (such as identifying C2 Education centers that may be located near to you).

G. Audio, electronic, visual, thermal, olfactory, or similar information, such as phone calls we record through our call center and footage recorded through security cameras at our education centers, which may collect visual information about you. We may also collect health and safety screening information (e.g., temperature checks, if applicable) In addition, with your permission, we may take photos of you and your students for marketing and other purposes.

Purpose:  We collect and use 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 may use photos of you and your students for marketing purposes.

H. Professional, education, or employment-related information, such as information relating to your position, (e.g., job title, job description, or department), employment status, employment history, or business email address. We may also collect or process the following professional or employment-related information from our job applicants: details in a resume, cover letter, references, job application materials, desired position, available start date, desired compensation and availability, immigration or work authorization status, relationship with the company or its current/former employees, work history, health, safety and environmental training, certifications, licenses, assessment results, language proficiencies, professional memberships, honors or awards, internships, school transcripts, and education records.

Purpose: We collect this information with respect to job applicant and candidates for employment process job applications and in connection with an applicant’s employment at C2.  We use parent employer information in connection with our provision of Services.

I. Inferences and profiles based on other personal information, such as information about your behavior, preferences, characteristics, aptitudes, or predispositions. For example, we may build profiles for our students based on: (i) information on a student’s education, including grades, activities and other information that would be provided in connection with college applications; (ii) student performance and scores on practice tests administered by C2 during tutoring sessions.

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. Where this data is collected from our job applicants, it will be used in connection with our recruitment activities.

J. Other information you voluntarily provide, such as information about your hobbies, interests, career goals, and other information.

Purpose: We collect this information in connection with providing tutoring and college counseling Services, and in connection with our recruiting processes.

We do not collect or process “sensitive personal information” (as defined by the CCPA) for the purpose of inferring characteristics about you. By providing us with personal information, you agree that you are authorized to provide us with such information. Where the information you are providing pertains to someone else, you acknowledge that you are required to inform them of the contents of this Privacy Policy. Information regarding any student that is a minor must only be provided by the student’s parent and legal guardian. It is your responsibility to ensure that the personal information you submit does not violate any third party’s rights.

How We Use Your Information

We use your information, including your personal information, and may have used your personal information in the 12-months prior to the effective date of this Policy, for the following purposes additional to those listed above:

• To provide our Site and Services to you such as test preparation, tutoring and college counseling services.
• To communicate with you about our Services, to respond to your inquiries, and for other customer service purposes.
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services.
• For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you.  We also may use the information that we learn about you to assist us in advertising our Services on third-party websites.
• To administer our employment and job recruitment processes.
• To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to operate, secure, and improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.
• Protecting the legal rights, property, safety, and security of records or information, our facilities, our customers, and website users, our organization and others, including detecting and preventing security incidents, fraud, misuse, harassment, and other malicious, deceptive, unauthorized, or illegal activity.
• Complying with industry standards, applicable law, judicial process, any properly authorized civil, criminal, or government or regulatory investigation or request, or any subpoena or summons issued by a competent authority.
• Enforcing our policies, terms of use, or rights arising from contracts.

In addition, we may also use, disclose, or otherwise process your personal information for such purposes as you may authorize at the time you submit the information or as otherwise compatible with the above purposes or your reasonable expectations.

We may de-identify personal information by removing any details that identify you personally. If we do so, we will maintain and use the de-identified personal information without attempting to re-identify it. De-identified personal information will not be subject to this Policy and will be used to the extent permissible under applicable law.

If you use our text messaging service, we may also use your information to:

• operate and provide you with the text message service;
• process and respond to your inquiries and let you know about products and information we think may be of interest to you;
• improve the text message service, including to understand how you use the text message service and to improve the text message service, our content, and user experience;
• contact you with important announcements or messages, if necessary;
• conduct research; and
• provide anonymous reporting for internal and external clients and partners.

For more information, please visit our Text Message Terms of Use.

How We Share Your Information

We may share your information, including personal information described above, and may have shared your personal information in the preceding 12-months, for the business or commercial purposes described above, to the following categories of entities:

• Franchisees and Affiliates. We may disclose the information we collect from you to our franchisees, affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
• 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.
• To Other Third Parties for Business Purposes. We may disclose your personal information to other third parties where disclosure is required for an ordinary business purpose in connection with our provision of our Site or Services, or in connection with our recruitment processes.
• 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 C2 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.

Sharing excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

We do not use sensitive personal information for purposes other than those allowed by the CCPA as set out in Cal. Code Regs. tit. 11 § 7027(m), nor do we sell or share the personal information of individuals under 16 years of age as those terms are defined under the CCPA.

Our business model does not include selling your personal information to third parties in exchange for money. However, depending on how you interact with us, we may share online identifiers and internet or other electronic network activity information, such as cookies and the advertising identifier associated with your computer or mobile device, with our marketing and advertising partners, including platforms that enable or participate in targeted and cross-context behavioral advertising, social media platforms, and analytics partners, to show ads that are targeted to your interests. Under certain state privacy laws, sharing personal information with partners in exchange for some benefit, such as providing more relevant ads, can be considered a “sale” or “sharing” in some circumstances. As such, we may be considered to “sell” or “share” or otherwise process your personal information for targeted or cross-contextual behavioral advertising. Apart from these “sales” we do not sell your personal information. You can learn more about our use of cookies and other similar technologies below.

Residents of certain states may opt out of the “sale” or “sharing” of personal information as described in What Choices Do I Have Regarding My Personal Information? below. Please note that the right to opt out applies only to “sales” or “sharing” of personal information and does not restrict our ability to disclose information to third parties for valid business purposes.

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. The information generated by the cookies may include your IP address, your browser type, the date and time of your visit, the pages you visit and the amount of time spent on each, your device’s operating system, your mobile device identifier, your geographical area, referring URLs, and other information on your interaction with 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).

Some of the tools we use on our website include session replay technology that helps us understand how visitors interact with our digital services, diagnose technical issues, and improve the user experience. Session replay tools can create a visual reconstruction of a user’s browsing session, such as pages visited, clicks, scrolls, and non-sensitive form interactions, so we can assess site performance, usability, and accessibility. We may also use conversation intelligence tools to facilitate and analyze certain telephone interactions with our business. When you call a phone number that we publish for marketing, sales, or support purposes, our service providers may route the call to our team, record the call audio, and generate a transcript to help us understand call outcomes, improve service quality, and measure the effectiveness of our advertising.

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 properly or at all.

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.

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.

Security of My Personal Information

Although we endeavor to safeguard your personal information using commercially reasonable precautions,  no method of electronic transmission or storage can guarantee 100% security.

To help protect your information 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.

Retention of Personal Information

We only retain personal information for as long as necessary to carry out the processing activities described in this Policy, including but not limited to providing the Site and Services, processing your job applications, compliance with applicable laws, regulations, rules, and requests of relevant law enforcement and/or other governmental agencies, and protecting our, our employees’, and our business partners’ and clients’ rights, property, or safety and the rights, property and safety of others. We may retain personal information for a longer period of time if a longer retention period is required or permitted by applicable law, as well as our records retention requirements and policies. We determine our retention and deletion periods according to the following characteristics:

• The scope, nature, and sensitivity of the personal information;
• The risk of harm from unauthorized use or disclosure;
• The purposes for which the information was collected and how long it is needed for those purposes;
• The period during which the information may remain accurate and relevant;
• Applicable legal, accounting, reporting, or regulatory requirements; and
• The potential need to retain records for legal claims or compliance audits.

For example, we may retain your personal information for longer periods of time, such as to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or comply with applicable laws. In specific circumstances, we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

What Choices Do I Have Regarding My Personal Information?

We may send periodic promotional or informational emails or text messages to you, such as when you sign up for our newsletter or for messages at the Site.  You may opt out of such communications by following the opt-out instructions contained in the message.  Please note that, where allowed by law, it may take up to 10 business days for us and our service providers to process opt-out requests.  If you opt-out of receiving communications 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.

Depending on your state of residence, you may have specific legal rights regarding your personal information. This section describes the legal rights that are available to some individuals and explains how to exercise them:

Right to know and access

Residents of certain states may have the right to request that we disclose what categories of personal information that we collect about them, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, and the categories of third parties with whom the business discloses personal information.  You may also have the right to request the specific pieces of personal information that we have collected about them.

Right to request deletion of personal information

Residents of certain states may also request that we delete any personal information that we have collected from them, provided that we may retain personal information as authorized under applicable law

Right to request correction of personal information

Residents of certain states may have the legal right to request that we correct the personal information we maintain about them, if that information is inaccurate.

Right to Portability

Residents of certain states have the legal right of portability, or the right to have us transfer their personal information to other persons or entities upon their request, subject to certain exceptions.

Right to Opt-out of Sale or Sharing

Residents of certain states have the legal right to opt out of the sale of their personal information or disclosure of their personal information for targeted or behavioral advertising.

Right to Non-Discrimination

Residents of certain states have the legal right to not be discriminated against for exercising their privacy rights.

Residents of states that provide the specific legal rights listed above may exercise their rights under the CCPA and submit your requests in one of the following methods: (a) by emailing us at [email protected]; (b) by calling the following toll free number at 888-312-3814. In order to address your request, we will need to verify your identity.  If your request does not provide us sufficient information to reasonably verify that you are the person about whom we collected personal information or an authorized representative, 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 needed to verify your identity.

For requests to know or delete information about a child under the age of 13, we accept requests for information regarding minors under the age of 13 if we can determine that such requests were submitted by a parent or guardian.

Authorized agents may initiate a request on behalf of an individual using the same methods described above. Authorized agents will be required to provide proof of their authorization, and we may also require that the individual directly verify their identity and the authority of the authorized agent. Individuals may also provide us with a signed and dated power of attorney naming the authorized agent as their representative.

We will respond to requests as required by applicable law. We may deny a request if we cannot verify identity or if the law otherwise permits. If we deny the request, we will explain the basis for the denial, provide or delete any personal information that is not subject to the denial, and refrain from using the personal information retained for any purpose other than permitted by the denial. Where required by law, we will also provide instructions on how the individual may appeal our decision or submit a complaint. In general, if applicable law grants the individual the right to appeal our denial of their request to exercise privacy rights, they may appeal the denial to us by emailing us at [email protected] or calling us at 888-312-3814.

Do Not Sell or Share My Personal Information. To the extent we “sell” your personal information or disclose your personal information for targeted or behavioral advertising, you may have the right to opt out of those “sales” or disclosures on a going-forward basis at any time. To exercise this right, visit the “Do Not Sell or Share My Personal Information” link in the footer of our webpage or our cookie consent platform.

You may also be able to restrict the collection of personal information through your device’s operating system or by disabling cookies, but doing so may prevent you from using the functionality of the websites. If your browser supports it, you can turn on the Global Privacy Control (GPC) to opt out of the “sale” or “sharing” of your personal data. We honor the GPC and other universal opt out signals where we are required to do so by applicable law. These are signals you can send from your browser to a website to convey your choice to exercise certain opt-out rights granted by individual states.

Some internet browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our website does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Even if you opt out of the sharing or processing of your personal information for targeted or cross-context behavioral advertising, you may still see our ads online at other sites and apps, and we may still base aspects of ads on your interactions with us and the websites.

Children Under 13

Our Site is not designed for children under 13. We do not knowingly collect, use, or share personal information from children under 13 without appropriate parental consent. If a parent or legal guardian learns that their child provided us with personal information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such personal information.

Transfers of Personal Information

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 C2 in the United States, which is a jurisdiction that 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 C2 collects, uses, and distributes.

Questions?

Should you have questions or concerns about our privacy practices, or would like to make a complaint please send an email to: [email protected] or C2 Educational Systems, Inc.; Attn: Customer Service; 6470 East Johns Crossing Suite 160 PMB 1046 Johns Creek, GA 30097.

Changes to this Policy

This Policy is current as of the Effective Date set forth above.  We may change this Policy from time to time, so please be sure to check back periodically.  We will post any changes to this Policy on our Site, at https://www.c2educate.com/privacy/.

92928013.v1-OGLETREE

92928013.v1-OGLETREE