Privacy Policy

We may sell the following categories of personal information (according to the broad definition of “sell” under select state privacy laws), or share them with third parties or for targeted advertising: personal identifiers (including names, email address, phone number, IP address, mobile advertising IDs) and internet or other electronic activity information (including your interaction with our website, other websites or platforms, and advertisements).
The third party recipients of this personal information are advertising networks, data brokers, and other companies that facilitate or engage in digital advertising.

We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals.

Our website and services are not directed to children under the age of 13. 

We do not engage in the automated processing of personal information to create profiles about individuals that are used in furtherance of decisions with legal or other similarly significant effects, such as the provision or denial of financial or lending services, housing, insurance, or access to essential goods or services.

We do not collect, use or sell personal information for the purpose of training large language models.

In the 12 months prior to the date of this Policy, we disclosed the following categories of personal information to our service providers and contractors for one or more business purposes:

• Personal identifiers: name, email address, your home or billing address, telephone numbers, IP address, account name and password
• Commercial and financial information: records of services ordered or considered; other purchasing or consuming histories; and payment information
• Health information: Customer-reported information about learning disabilities or other health conditions
• Internet or other electronic activity information: your device and browser type, your browsing and search history on our website, and information regarding your interaction with our website and our advertisements
• Education information: educational institutions attended, degree information, grades or grade information, classes or courses taken, certificates obtained, honors received, educational interests, internships or part-time jobs
• Audio and visual information: audio recordings of sessions and customer service calls; visual information collected during online sessions
• Inferences drawn from personal information we collect

We disclose personal information for the following business purposes: to manage customer, supplier and vendor accounts and relationships; process payments; verify customers’ identities; provide our services; engage in advertising and marketing; operate our IT systems and secure our systems; prevent fraud and other illegal activities; and to obtain professional advice about legal and accounting matters.    

We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also disclose your personal information to other persons or entities to help detect and protect against fraud or data security vulnerabilities. We may also disclose or transfer your personal information in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

We may use cookies, pixel tags, web beacons and other similar tracking technologies (“tracking technologies”) to automatically collect information through our website. Tracking technologies are small data files placed on your computer, tablet, mobile phone, or other devices that record certain pieces of information when you visit our website. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as making it possible for you to save your preferences and help us understand how you interact with us.  

We also allow third parties (including Google and LinkedIn) to use third party cookies, web beacons, and other storage technologies to collect or receive information about how you interact with our websites and apps and elsewhere on the Internet and use that information to provide analytics and other measurements services, and to deliver and target advertisements tailored to you. Third parties may also use some of these technologies to assist us in determining if you require assistance or are having problems navigating on our websites or apps, and this may include technologies that record your interactions with the website or app, including without limitation, your keystrokes, mouse clicks, screen touches, and information about when, how and from where you accessed our website or app. Residents of some states have rights to opt out of the use of tracking technologies for some purposes. See the U.S. State Data Privacy Rights section below for more information. 

You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.

We use Google Analytics to evaluate the use of our website and we also use services provided by Google Ads. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a Site, what pages they visit when they do so, and what other websites they visited prior to visiting our website. For information about Google’s privacy practices, please refer to the Google Privacy Policy: https://policies.google.com/privacy?hl=en-US#infocollect.

We retain the categories of personal information we collect for the length of time necessary to provide our services and to comply with legal obligations or to protect our legal rights.

If you have consented to receive text messages from us, you may receive text messages about our services. Message rates may apply and messaging frequency may vary. You may opt out of text messages by texting STOP to the number from which we send SMS messages. For additional information, you can text HELP to the number from which we send SMS messages. Links to our Terms of Service and this Privacy Policy may also be provided.

Our website may contain links to third-party websites, including social media buttons that link to social media platforms. This Policy does not govern how those third parties or social media platforms collect or use personal information and we do not endorse or have control over their practices. The privacy policies and terms of use for those third parties’ websites/apps or social media platforms govern those companies’ privacy practices. We are not responsible for the content or privacy practices of any third-party websites or platforms.

We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process.  However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination.  Accordingly, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.

We will review and update this Policy from time to time.  If changes are made, we will update the Privacy Policy and reflect the date of such modification in the date above. If the changes are material, you will be notified via a notice on our website.

Consumer Rights Under Comprehensive U.S. State Data Privacy Laws 

We provide residents of the following states with rights with respect to the personal information we may collect about them under their state’s data privacy law: Colorado, Connecticut, Montana, Nebraska, and Texas. The rights provided under these laws are similar in many respects, with some differences from state to state, and are subject to all applicable exceptions.

• Right to Know: The right to know whether we are processing your personal information.
• Right to Access / Copy: The right to access or request a copy of your personal information.
• Right to Delete: The right to request deletion of your personal information that we have collected about you.
• Right to Correct: The right to request that we correct inaccuracies in your personal information.  This right is not available under Iowa or Utah privacy law.
• Rights to Opt Out:  Various rights to request that we stop using your personal information for the following purposes:
  • Sale of Personal Information: The right to request that we stop selling your personal information, consistent with the definition of “sale” under applicable state privacy laws.
  • Targeted Advertising: The right to request that we stop processing your personal information for targeted advertising as defined under applicable state privacy laws.

Exercising Your Rights

We will respond to requests from residents of states with data privacy laws that apply to us and will do so with respect to the rights that are provided as of the effective date of each law.

To exercise applicable rights other than opt-out rights, submit a request by contacting us at privacy@commandeducation.com.

To exercise opt-out rights, click here.

Opt-out Preference Signals and Do Not Track

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests.  The signal can be set on certain browsers or through opt-out plug-in tools.

We recognize the Global Privacy Control signal when sent from IP addresses from Colorado, Connecticut, Montana, Nebraska, and Texas. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).

We do not respond to the DNT or “Do Not Track” signal.

Exercising Your Rights Using Authorized Agents

Agents may submit opt-out requests on behalf of individuals who are residents in Colorado, Connecticut, Montana and Nebraska.  They can submit such requests by contacting us at privacy@commandeducation.com.

Verification of Requests

When you exercise rights other than opt-out rights, we will take steps to verify your identity.  We will ask you for at least two pieces of personal information, depending on the nature of the request, and attempt to match those to information that we maintain or collect about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request.  We will notify you to explain the basis of the denial.

When We Do Not Act on a Request

In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.

Additionally, residents of Colorado, Connecticut, Montana, Nebraska, and Texas have the right to appeal our decision by contacting us at privacy@commandeducation.com within 30 days after your receipt of our decision.

California Shine the Light

With reference to California Civil Code Section 1798.83, also known as the “Shine the Light” law, we allow California residents to opt out of the disclosure of personal information to third parties for those third parties’ direct marketing purposes.  To exercise this opt-out option, click here.

Non-Discrimination

If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly.

To make accessibility-related requests or report barriers, please contact us at privacy@commandeducation.com or (212) 368-1000.

If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format you may contact us at privacy@commandeducation.com or (212) 368-1000.