EFFECTIVE DATE: January 1, 2020
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.
The Information We Collect About You
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 at one of our locations, 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”).
- Student performance and scores on practice tests administered by C2 (“Testing Information”) and during tutoring sessions (“Tutoring Information”).
Information We Collect Automatically
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- To provide our 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 better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.
How We Share Your Information
We may share your information, including personal information, as follows:
- 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.
- 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.
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.
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
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 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 firstname.lastname@example.org.
If you have questions about the privacy aspects of our Site or would like to make a complaint, please contact us at email@example.com or C2 Educational Systems, Inc.; Attn: Customer Service; 6465 E. Johns Crossing, #100; Duluth, GA 30097.
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 C2, or a California resident that reasonably believes that C2 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: firstname.lastname@example.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 email@example.com 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 firstname.lastname@example.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 C2 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 C2 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 C2. 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.
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 C2. 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. The categories of personal information disclosed include those listed in Sections A though K above.
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: email@example.com or C2 Educational Systems, Inc.; Attn: Customer Service; 6465 E. Johns Crossing, #100; Duluth, GA 30097.
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 C2 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 C2 collects, uses, and distributes. Should you have questions or concerns regarding your personal information please send an email to: firstname.lastname@example.org or C2 Educational Systems, Inc.; Attn: Customer Service; 6465 E. Johns Crossing, #100; Duluth, 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/. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.