Updated January 10, 2020. Effective January 10, 2020.

Compass Education Group provides personalized one-on-one tutoring to students preparing for standardized tests all over the world. We provide a variety of services and resources through the web at compassprep.com and on mobile devices and tablets through the Compass Prep application. As used in this policy, “Compass” refers to Compass Education Group, LLC and its subsidiaries. This policy applies to all Compass-authorized operations. We may refer to Compass as “we”, “us”, or “our”. We may refer to you as “you”, “your”, “client”, or “student”. The purpose of this policy is to inform you about the personal information we collect, how we use and share that information, and the ways in which you can control how we use and share your information. By accessing our website or app, you agree to the terms of this policy and you expressly consent to the collection, use, and disclosure of your personal information in accordance with this policy.

I. Information we receive or collect from you
    1. Requests for information/Requests for us to contact you: There are various contact forms on our website which allow you to request more information from us. These forms ask you to provide certain information including your name, gender, phone number, email address, location, student’s school, student’s graduating class year, your relationship to the student, and the services you’re interested in.
    2. Sign-up forms: When Compass hosts events such as presentations and practice tests, we may ask that you complete a registration form. These forms ask you to provide certain information including your name, gender, phone number, email address, location, student’s school, student’s graduating class year, your relationship to the student, and the services you’re interested in.
    3. Payment Information: Should you choose to take a practice test with us or enroll in our tutoring services, we may collect payment information from you.
    4. Information you choose to provide to Compass: You may provide a variety of information about yourself or your student during your interactions with us and our services, such as emails you may send us, appointments you schedule with us, and emails or newsletters that you sign up to receive. Compass and the third parties acting on our behalf receive data from you whenever you provide us with information.
    5. Community Posting: You have the ability to comment on our blog posts. To share these comments, we ask that you provide your name and email address. The content of your comments and the information you choose to provide about yourself or your student may be made visible to the public. We are not responsible for the personal information you post publicly.
    6. Access information: When you access our website or application, we may collect certain information about how you’ve accessed our services. This information may include IP address, browser type, device type, software, operating system, or hardware information, date/time stamps, location, and language.
    7. Research and feedback: If you choose to participate in any surveys, we will collect the information you provide to us through those surveys.
    8. Third party personal information: Certain contact forms ask you to provide information about your student (if you are a parent/guardian) or your parents/guardians (if you are a student). By providing another person’s personal information to us, you confirm that you have all the necessary rights and permissions to provide such information. If you provide this information to us, we may store it. 
II. Information we receive or collect from third parties

We may receive or collect information about you from third parties, and combine and store it with other information we may have already received or collected from you. These third parties include:

    1. The high school the student attends.
    2. Partners that provide advertising, features, functionality, and content to our website, application, or services.
    3. Social media services that you use.
    4. People who share or post information about you on our blog or who contact us and include information about you in their message.

Compass is not responsible for, and will assume no liability, if a business partner or other entity collects, uses, or shares any information about you in violation of its own privacy policy or any applicable laws, rules, or agreements.

III. Information collection technologies
    1. Cookies: Compass uses a technology that is commonly known as “cookies.” A cookie is a file our server writes to your hard drive that contains an alphanumeric identifier. We use the identifier in a cookie to help us manage and report on your interaction with us. Through cookies, we are able to collect information that we use to improve our services, keep count of return visits to our website, collect and report on aggregate statistical information, authenticate your login credentials, or manage multiple instances of our sites in a single browser. We may also collect other data such as the page or site that referred you to us, the date and time you visited the website, and your current IP address. The cookies we place on your hard drive are known as “first-party cookies.” We use both session cookies and persistent cookies. A session cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You may be able to remove persistent cookies by following directions provided in your browser’s “help” section. If you do not accept first-party cookies you may still access our website, but your ability to use some areas of our website, and the ability to stay logged in, will be limited.
    2. Advertisers’ and other third parties’ use of cookies: Advertisers and third-party partners may place or recognize a unique cookie on your hard drive. These types of non-Compass cookies are known as “third-party cookies.” Advertisers and third-party partners may use third-party cookies in order to collect information about you. Most major web browsers provide users with the option to accept or reject third-party cookies. The use of third-party cookies is not covered by this privacy policy. We do not have access to or control over cookies placed by advertisers and other third parties.
IV. How we use the information we receive or collect
    1. We do not sell your information to other companies. We do use your information to contact you and provide you with news, resources, information, offers, and updates and results from services you’ve engaged in.
    2. Compass may use the information and data we receive or collect from you for a variety of purposes:
      1. For the purposes for which you provided it
      2. To create and secure your account
      3. To provide and improve our services, and to develop new products and services
      4. To customize and personalize advertising and messaging, and to provide you with relevant and interesting content
      5. To measure and analyze the usage of our services. We use tracking information to determine which pages on our website perform well and how we can build a better service for you
      6. To fulfill your requests for information, such as providing you with more details about our company and the services we offer, sending you electronic newsletters, and allowing you to continue to use our paid services
      7. To inform you of the newest developments and features of our services and to communicate to you information about security and maintenance
V. How we share information we receive or collect with others
    1. We contract and partner with third parties to provide specialized services on our behalf, such as credit card processors, data storage, customer support, ad servers or other providers of advertising services, platform technology providers, bulk email processors who send out emails on our behalf, postal mail providers, or parties who assist us with scheduling and appointment management. These companies are authorized to use your personal information only as necessary to provide these services to Compass. They are not authorized to use your personal information for their own, unrelated purposes.
    2. When you participate in community and social networking features through Compass (for example, commenting on a blog post), you elect to share any information you’ve posted on that public platform. You should be aware that any information you share in these postings can be read, collected, and used by others who access these public platforms.
    3. We may share information we’ve collected about a student with other authorized personnel on their account. For example, we may send practice test results to the student’s family members or college counselor.
    4. If a student engages in services provided through their school, such as taking a practice test or attending a presentation, we may share that information with faculty and staff at the school.
    5. To measure and analyze the performance of our services and resources. For example, we use Google Analytics, and other Google services, to track consumer behavior on our website and through our mobile and tablet application. We also use services like Survey Monkey to measure customer satisfaction.
    6. Legal and Security Purposes: We may share your information in order to (i) protect or defend the legal rights or property of Compass, or the legal rights of our business partners, employees, agents, and contractors (including enforcement of our agreements); (ii) protect the safety and security of Compass users or members of the public including acting in urgent circumstances; (iii) protect against fraud or to conduct risk management; or (iv) comply with the law, legal process, or legal and government requests. 
    7. Compass may share with third parties, advertisers, and/or business partners deidentified, aggregated, or anonymized information we receive or collect, such as demographic information, location information, or information about your interactions with our services. We share such information for a variety of reasons, such as to analyze usage and improve our services and advertising, or for other similar purposes.
    8. We do not sell your data to any third parties.
VI. Managing your information
    1. Modification of your information: If you have an online account with us, you have the ability to modify some of the data in your profile through account settings.
    2. Retention of your information: We will store your information in our systems for as long as is necessary to provide our services. We also maintain a central database of consumers who have created accounts with us.
    3. Your email preferences: When you share your email address with us, you may elect to receive promotional, marketing, or other similar emails. You have the option to unsubscribe from these emails, by following the instructions in those emails. You may also request to be put on a “Do Not Mail” list by contacting us directly. However, we may still send you some emails when it is necessary to do so (for example, to provide you with a billing statement).
VII. Security
    1. Protection of Data from Loss: We have implemented security measures designed to protect against the loss, misuse, and alteration of the information we collect or receive from you. However, despite our efforts, no security measures are perfect or impenetrable. If you have any questions about our security, you can contact our support team at support@compassprep.com
    2. Data Integrity: We use the information we collect in ways that are relevant and compatible with the purpose for which that information was collected or provided to us as disclosed in this policy. We will take steps to ensure that all information collected, processed, and/or stored is protected from destruction, corruption, or use in a manner inconsistent with our policies or the purpose for which we received it.
    3. Links to Other Websites: Our website and some correspondence from us may contain links to other websites whose privacy practices may differ from those of Compass. If you submit personal information to any of those websites, the privacy statements and practices of those websites govern their use of your information. We encourage you to carefully read the privacy statement of any website you visit.
VIII. The use of our services by children
    1. The use of our online services is not intended for persons under the age of 13. By using our online services you hereby represent that you are at least 13 years old. If you believe we have collected data on a child under the age of 13 without parental consent, please contact privacy@compassprep.com
IX. Your rights under laws
    1. California Residents: Pursuant to California Civil Code Section 1798.83, this policy sets forth that we only share personal information (as defined in California Civil Code Section 1798.83) with third parties for direct marketing purposes if you either specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out of such sharing at the time you provide personal information or when you choose to participate in a feature of our services. If you do not opt-in or if you opt-out at that time, we will not share your personal information with that identified third party for direct marketing purposes. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. Like many other websites and online services, we do not currently alter our practices when we receive “Do Not Track” signals as there is no consensus among industry participants as to what “Do Not Track” means in this context. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com/.
      California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their ‘personal information’ (if any, and as defined under applicable California law) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email at privacy@compassprep.com
    2. Nevada Residents: If you are a resident of Nevada, you may apply limits to the sale of certain personal information to third parties for resale or licensing purposes, subject to applicable law. Compass does not sell your personal information for such use. You are entitled to register your preference for limits on such sales in the future by sending an email to privacy@compassprep.com, with the subject line, “Nevada Do Not Sell Request” along with your first and last name, zip code, and whether you are a former or current Compass client. If you are a former or current Compass client, in order to process your request, your email address must match the email address on your account.
    3. European Residents: You have rights under the GDPR. To exercise your rights (defined below) please send a request via email to privacy@compassprep.com or via mail to our postal address.
      1. Revocation of Consent. You can revoke your consent – in those cases where consent for processing is necessary – for future data processing at any time. However, this does not affect the lawfulness of data processing based on the consent before the revocation. In certain cases, we may continue to process your information after you have withdrawn consent, if we have another legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
      2. Right of Access. You have the right to obtain (i) confirmation as to whether or not your data is being processed by us and, if so, (ii) more specific information on the data. The more specific information concerns, among other things, processing purposes, categories of data, potential recipients, or the duration of storage.
      3. Right to Rectification. You have the right to obtain the rectification of inaccurate data concerning you from us. In case the data processed by us is not correct, we will rectify these without undue delay and inform you of this rectification. Please note that (i) you can rectify much of your information in the settings and (ii) it is not technically possible for us to rectify all kinds of data in our Product.
      4. Right to Erasure. You have the right to delete data we store about you. Should you decide to do so, please contact us. As a safety measure, we will send you an email in order for you to confirm this deletion. We will delete your data after this confirmation.
      5. Right to Restriction of Processing. You have the right to obtain a restriction of processing of your data from us in the following cases:
        1. you make an inquiry pursuant to data erasure, if you so request;
        2. you are of the opinion that the processing of your data is unlawful, but are opposed to an erasure of Data;
        3. you still require the data for the establishment, exercise or defense of legal claims; or
        4. you have objected to the processing pursuant to erasure.
      6. Right to Data Portability. You have the right to (i) receive a copy of your Data in a structured, commonly used and machine-readable format and (ii) transmit those data to another controller without hindrance from us.
      7. Right to Object. You have the right to object at any time to the processing of data for which our legitimate interests are the legal basis, including profiling based on those provisions. You also have the right to object to processing of data for direct marketing purposes.
      8. Right to File a Complaint. You have the right to file a complaint with your local supervisory authority, if you think that the processing of data infringes applicable law.
X. Transfer of information for international consumers
    1. If Compass services are offered outside of the U.S., the information you submit to us may be transferred to the U.S. and other countries to be processed by us or our service providers in order to provide service to you or for such other purposes as set forth in this policy. If you are not a resident of the U.S., you hereby consent and agree that we may collect, process, use, and store your information, as discussed in this policy, outside your resident jurisdiction, including in the U.S. Please be aware that U.S. law and the laws of other countries where we may store and process your information may offer different levels of protection for information than may be available in your country.
XI. Changes to our privacy policy
    1. Compass reserves the right to change this Privacy Policy at any time. We will continue to evaluate this policy against new technologies, business practices, changes in law, and our clients’ needs, and may make changes to the policy accordingly. Please check this page periodically for updates. If we make any material changes to this policy, we will post the updated terms of the policy on our website, and provide you with notice of such changes, which may include an email sent to the email address you provided to us.
XII. Contact Us
    1. If you have any questions about this privacy policy, or Compass’s privacy practices, contact us by phone at (800) 685-6896 or email at privacy@compassprep.com or physical mail at Compass Education Group, LLC, 9100 Wilshire Blvd. Ste 520E, Beverly Hills, CA 90212 USA