This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
You may exercise your California privacy rights described above as follows:
We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
The charts below summarize how we collect, use and share Personal Information by reference to the statutory categories specified in the CCPA, and describe our practices during the 12 months preceding the effective date of this Privacy Policy. Categories in the chart refer to the categories described above in the general section of this Privacy Policy.
| Statutory category of personal information (PI) | Source of the PI | Purpose for collection | Categories of third parties to whom we “disclose” the PI for a business purpose | Categories of third parties to whom we “sell” the PI |
|---|---|---|---|---|
| Education Information | Customer | Operations | Service-related third parties; professional advisors | None |
| Geolocation Data | Customer | Operations | Service-related third parties; professional advisors | None |
| Identifiers | Customer | Operations | Service-related third parties; professional advisors | None |
| Inferences | Customer | Operations | Service-related third parties; professional advisors | None |
| Online Identifiers | Customer | Operations | Service-related third parties; professional advisors | None |
| Professional or Employment Information | Customer | Operations | Service-related third parties; professional advisors | None |
| Protected Classification Characteristics | Customer | Operations | Service-related third parties; professional advisors | None |
| Statutory category | Definition (categories may overlap) | What we collect |
|---|---|---|
| Education Information | Personal information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates. | Name of school(s) attended Dates of attendance Degree(s) earned Certification(s) earned |
| Geolocation Data | Precise location, e.g., derived from GPS coordinates or telemetry data. | — |
| Identifiers | Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. | Name Alias Postal address Telephone number Email address |
| Inferences | The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. | May be derived from your: Device data Online activity data |
| Online Identifiers | An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device. | Device data Identity data |
| Professional or Employment Information | This term is not defined in the CCPA, but likely includes any information relating to a person’s current, past or prospective employment or professional experience (e.g., job history, performance evaluations). | Current and past job history Job Title |
| Protected Classification Characteristics | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Sex/Gender Age (may be inferred from birth date) |
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