Policy Privacy

Last updated: December, 23 2024

1. Your privacy is really important to us when using the Foundation for a College Education websites, services, or otherwise engage with the Foundation of College Education (collectively the “Service”). You are trusting us with your data, and we want to make sure it’s safe, secure, and handling in a responsible manner. In this Privacy Policy (the “Policy”) Foundation for a College Education (“FCE”, ” us”, ” our”, and ” we”) commits to protecting your data and outlines what data we collect and how it is used. We reserve the right to update this Policy and will post any changes here. We comply with applicable data protection legislation, which includes but is not limited to the California Consumer Privacy Act of 2018 and any binding regulations promulgated thereunder, in each case, as may be amended from time to time. This includes but it is not limited to the California Privacy Rights Act of 2020 (collectively “CCPA”). FCE recognizes the importance of privacy, and this Policy is to help you understand and describe how we collect, use, and disclose your data:
   2. Collection and use of information
   3. Sharing your data
   4. Categories of data
   5. How we use your data
   6. Security of your data
   7. Use of third-party services
   8. Your Privacy Rights
   9. Cookies
   10. Children’s data
   11. Users outside the US
   12. Changes and contacting us
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2. Collection and use of information.
   1. We collect data about you directly from you and automatically through your use of our Service. We may combine data automatically collected with other data that we have collected about you including from publicly available sources. We encourage you to provide only that data that is necessary for using our Service.
   2. Data collected automatically. Like many websites, technologies to receive and store certain types of data when you interact with us through your device. Using these technologies helps us customize your experience with our Service and improve your experience.
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3. Sharing your data.
   1. We do not sell your data to any third parties or disclose it in exchange for money or other valuable consideration. We do not share your data with others except as indicated within this Policy, or when we inform you at a subsequent time.
   2. We may share your data as follows:
      1. With third-party service providers, contractors, or government entities.
      2. We use third-party service providers services on our behalf or to assist us with providing services to you such as: to process payment card transactions, sending emails hosting, IT services, or customer service;
      3. For search engine optimization (“SEO”) purposes and for serving you the most relevant advertising;
      4. With service providers and government entities for legal, security, and safety purposes. This includes sharing data to enforce policies or contracts, address security breaches, and assist in the investigation of fraud, security issues, or other concerns.
      5. If we believe that disclosure is reasonably necessary to comply with a law, regulation, legal, or governmental request; to enforce applicable Terms of Service or this Policy.
      6. For our own internal business purposes including but not limited to product improvement in aggregated, anonymized, and/or de-identified form that cannot reasonably be used to identify you.

4. Categories of data. When using FCE, we collect information including but not limited to the following potentially personal data:
   4. Email: This is used as your account login, and we may occasionally send emails communicating to you. We will not share this with any third party that’s not necessary for the product to function (e.g. it would be shared with our authentication provider). We will not share your information or email to any third party that is not necessary.
   5. Entries and Conversations: when you put down thoughts or talk with coaches or otherwise input data into the Service – that is information that is ultimately stored and used in the Service.
   6. AI Artifacts: there are likely artifacts that are generated from your entries and conversations (e.g. summary, questions, themes); we treat artifacts such as summaries the same as your raw entries and conversations and treat with the same encryption method.
   7. Phone Number: If you optionally set up text message reminders or other phone functionality, your phone number will be stored. We will not share your phone number to any third party that is not necessary for the product to function.
   8. In addition to this information, we may collect information such as browser metadata and how often you log in, what features you use in the product etc. in order to help us understand high level analytics of how the product is used.
   9. Identification data: name/s and surname/s; address; social security number (SSN), financial, or banking data, if applicable (such us, billing information, in particular), and demographic data.
   10. Academic and professional data: training/qualifications, student records, education records, learning history, professional experience, membership of professional associations, among others, if applicable.
   11. Giving testimonials concerning to the provided services, which may be sent by the client to FCE, and we may then post to our sites.
   12. Clients’ records after the Services are rendered.
   13. Any other information you choose to submit to the Service.

5. How we use your data. We may use data we collect about you to:
   5. We will use your data to provide our Service to you; we use the payment data you provide to us in order to alert you of, to allow us to present the billing history, and to perform internal financial processes.
   6. Improve our offerings. Analysis about your use of, or interest in our offerings.
   7. We may send you service emails to ensure the Service is working properly.
   8. Subject to your preference, we may send you emails about new features or offerings or other news about FCE or on topics we think would be relevant to you.
   9. We may contact you to inform you about changes in your services, our service offering and other important service-related notices.
   10. To communicate to you information related to the Service, news and value-added improvements, as well as related activities and training.
   11. If you apply to a job position in FCE (including volunteer positions), when you send us your application to participate in a job application process.
   12. To post Your testimonials or any relevant experience with the aim to show the day-to-day activity of FCE.
   13. To detect, investigate and prevent activity, we think may be potentially illegal, unlawful or harmful and to enforce our Statement or any other purpose referenced herein or therein.
   14. We may use your data to comply with applicable legal obligations as well as to protect our rights and interests as well as the rights and interests of our users and any other person.

6. Security of your data.
   6. We take reasonable and appropriate steps to protect the data entrusted to us and treat it securely in accordance with this Statement. We implement safeguards designed to protect your data from accidental/unlawful destruction, loss, alteration, and unauthorized dissemination. We will retain your data as needed to fulfill the purposes for which it was collected or as needed to fulfil our business needs or legal requirements. In the event that a security issue arises, we will disclose any relevant information via email or our social media channels.
   7. We have implemented technical and organizational measures designed to protect the data and protect its security, availability, integrity and confidentiality.
   8. Data collection is limited to the purposes of processing (or the data that You choose to provide).

7. Use of third-party services. The use of third-party services and software libraries is necessary to help power features of FCE. To enhance the services we offer and maintain the operation of our websites, we engage third-party service providers to assist with various functions. These providers help us with tasks such as website hosting, data analysis, payment processing, communication, and other related services. In the course of providing these services, third-party providers may have access to certain personal data necessary to perform their functions. Please note that while we take all reasonable measures to safeguard your data, these third-party services are governed by their own privacy policies, and we are not responsible for the privacy practices of these providers. We encourage you to review their privacy policies to understand how your information may be used.

8. Privacy Rights.
   8. THIS INCLUDES CCPA in (AND OTHER STATES [INCLUDING BUT NOT LIMITED TO VIRGINIA AND COLORADO)] AND OTHER APPLICABLE LAWS FOR PRIVACY RIGHTS.
   9. The following disclosures are intended to provide additional information about: the categories of personal data we collect the source of the personal data; how we use each category of personal data; and how we disclose personal data. These disclosures do not limit our ability to use or disclose information as described above.
      8. Category of personal data: Name, e-mail or user ID, profile password, gender, phone number, payment details, date of birth, geolocation, and any other conversation content that might be generated by you on the Service or your use of the Service.
      9. Sources of personal data: directly from you, third-party sites or sources such as our trusted business partners, analytics tools, and social networks.
      10. Use of personal data: deliver the Service to you, provide you information and communicate with you about your account and usage such as about your payments or transaction history, provide you promotions, enhance and personalize your user experience. Lastly, to improve our Service as well as build new services in the future.
      11. Disclosure of personal data: our affiliates, our services providers such as for hosting the Service, processing payments, and communicating with you.
   10. To the extent provided for by law, you may have the following privacy rights:
       8. The right to know what personal data we have collected and how we have used and dis closed it;
       9. The right to request deletion of your personal data; and
       10. The right to be free from discrimination relating to the exercise of your privacy rights.
   11. We do not and will not sell or share (as defined by CPRA) your personal data.
   12. Exercising Your Rights: Data subjects can exercise the above privacy rights by emailing us at EMAIL.
   13. Verification: in order to protect your personal data from unauthorized access or deletion, we may require you to verify your identity before you can submit a privacy request to know or delete personal data. In order to keep your data accurate and complete, you can log in to review and update your Account data.
   14. You may also contact us to: request the personal data we have collected from you or request the rectification or deletion of such data. We will do our best to honor your requests subject to any legal and contractual obligations. If you do not wish to receive promotional emails from us, you may opt out at any time by using the link in the email itself. Please note that it may take up to ten (30) days to process your request.
   15. Authorized Agent. You may submit a request to know or a request to delete your personal data through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency.

9. Cookies.
   9. Our Service use cookies and other similar device identification technologies (collectively “cookies”) to provide our services, to understand how they are used, and for analytics, personalization, customization and marketing purposes. personal data, such as your email address, may be collected through the cookies.
   10. Cookies may also be set by the Services feature to enable it to function properly. Information collected by these cookies is governed by the privacy policy of the company that created it.
   11. What are cookies? We use the term “cookie” to refer to all technologies which store and access information on the device that you use to access our services, such as your computer, tablet, or mobile phone. For example, we use HTTP cookies (web/browser cookies), which are small data files (typically made up of numbers and letters) that are downloaded when you access our services and allow us to recognize your device.
   12. Cookies enable websites to recognize your device and are often used to help the website function properly and to provide information to the owner(s) of the site. Cookies are necessary to recognize or “remember” anything about visitors.
   13. First party cookies: these are sent and are managed by FCE.
   14. Third-party cookies: these are not owned managed by FCE, but by another entity.
   15. Further information:
       9. When you visit our sites or otherwise interact with our Service, we and our service providers acting on our behalf automatically collect certain data using tracking technologies like cookies, and similar technologies. We use this data to understand how visitors to our websites are using them and which pages and features of the websites are most popular. This helps us understand how we can improve our websites and track performance of our advertisements.
       10. In addition, we use tracking technologies to help improve the navigation experience on our Service. We don’t sell this information to third parties.
       11. Cookies and similar technologies are pieces of data contained in a very small text file that is stored in your browser and/or device. These allow our Service to identify your device as you navigate our Service.
       12. By themselves, cookies do not necessarily identify you specifically, instead they recognize your web browser or device.

10. Children’s data.
    10. You must be at least thirteen (13) years of age to use the Service, or you must have verifiable parental consent. If you are under the applicable age of majority and do not have verifiable parental consent, you shall not use and are not permitted to use the Service and you must immediately leave the Services. By Using the Service, you represent and warrant that you have reached at least the age of thirteen (13) and the age of majority in your jurisdiction. We maintain a zero-tolerance policy for any minors on the Service.
    11. We do not knowingly collect personal data from anyone under the age of 13. If we discover that a person below 13 years of age or younger has provided personal data to us, we automatically delete such information. If you are a parent or guardian of a minor under the age of 13 and believe he or she has disclosed personal data to us, please contact us at EMAIL.

11. Users outside the United States. If you are an individual located in another jurisdiction outside of the United States (“US”) or the European Economic Area, United Kingdom, or Switzerland (collectively “EEA”) with laws governing data processing that differ from US or EEA laws, please be aware that data we collect will be processed and stored in the US or in other countries where we or our service providers have operations. Your use of the Service is voluntary and you are doing so with a full understanding that by submitting your data to FCE, you understand and acknowledge to have your data transferred to, US or another jurisdiction which may not offer the same level of privacy protection as those in the country where you are located.

12. Changes and contacting us.
    12. This Statement is current as of the Effective Date set forth above and if any changes are made, we’ll post them on this page. If you continue to use FCE after those changes are in effect, you agree to the changes. This Statement may change if there is a material change to the way data is processed by FCE.
    13. If you have any questions or comments about this Statement, please contact us at EMAIL or 687 Bay Road, Menlo Park, CA 94025.