Learners Edge, LLC (“Company,” “We” or “Us”) is committed to respecting the privacy rights of visitors to the websites operated by or for Us, including without limitation, www.passprepproduc.wpenginepowered.com and www.passageprep.com, and all subdomains, all local or toll-free call and mail processing centers, and all social media accounts held or operated by Us (collectively, the “Site”), and all live streaming, on-demand, videos, content, job postings, shopping and other services (collectively, “Services”) made available or provided from the Site.  Company has adopted the privacy policies outlined below (this “Privacy Policy”), which serve as the basis for our use of personal information gathered when you interact with Company, such as when you visit the Sites or when you contact our customer support agents. This Privacy Policy is intended to comply with privacy laws applicable to Company and the operation of the Site and the Services. 

WHAT TYPE OF INFORMATION DOES COMPANY COLLECT?

We collect three types of information about users: (1) Personal Information, (2) De-Identified Information and (3) Aggregate Information:

  • “Personal Information” is collected online when users voluntarily submit non-public personal information by signing up for our newsletter, registering for an account on the Site, purchasing courses or services or other items using our shopping cart, or sending or receiving electronic notices or other similar communications on the Services. Personal Information may include  name, email address, IP address, phone number, the state in which you are seeking licensure, physical address, mailing or shipping address, billing address, age, gender, educational history, employment history, resume, credit card, check or other payment processing (such as Masterpass or PayPal), social media user name or ID, computer/device and other similar personally identifiable information. When you access or browse the Site or Services,  your IP address may be collected automatically for purposes of enhancing browsing via cookies or standard settings. Your Personal Information will be retained for fulfillment of the intended purposes for which such Personal Information is collected.  
  • “De-Identified Information” (such as statistical information on Site usage and data and technical requirements) is collected online information in which all personal and individually identifiable identifiers have been removed by Company.  De-Identified Information is used in a collective manner for analyses and statistics in order to improve the Services.  De-Identified Information does not personally identify a specific user or such user’s geographic location.
  • “Aggregate Information” (such as information about how many users log on or call to the Site on a daily basis) is non-personally identifiable (or anonymous) information about you, such as pages most frequently accessed by you. Aggregate Information is used in a collective manner, and no single person can be identified by that compiled information (for example, the number of people who logged into the Site in a particular day).  Aggregate Information does not personally identify a specific user. 

We will establish minimum and maximum retention periods based upon the type of information collected (i.e. sensitivity), the intended purposes and as otherwise may be legally required. 

Personal Information shall NOT include any personal information posted or sent by or to you in any public forum (such as a posting on our social media accounts) available or assessed from the Site.  Participation in these public forums requires the public release and dissemination of such information, and thus Company cannot commit to treating such information confidentially in the same manner that other personal information will be treated under this Privacy Policy.  Participation in these features of the Site is voluntary and thus your consent to certain terms is required before participation is allowed.  

For the sake of clarity, we do not collect the personal information of students from student records created or maintained by an educational institution (e.g., a district, college, university, etc.) through the Site or Services.

HOW DOES COMPANY SECURE MY PERSONAL INFORMATION? 

Company maintains commercially reasonable safeguards to ensure the security, integrity and privacy of the Personal Information provided by you. Such security safeguards are intended to be appropriate to the sensitivity of the Personal Information collected.  To the extent that Company transfers any Personal Information to third parties, we will use commercially reasonable efforts to assure that such third parties to whom we may transfer any Personal Information have knowledge of our Privacy Policy and provide sufficient protection of such Personal Information. Company is committed to properly securing the Personal Information collected online.  To help us accomplish this, we take the following steps:

  • We employ internal access controls to ensure that the only people who see your Personal Information are those with a need to do so to perform their official duties.
  • We train relevant personnel on our privacy and security measures and applicable legal requirements.
  • We physically secure the areas where we hold hard copies (if any) of the Personal Information that we collect or process.
  • We use technical controls to secure the Personal Information that we collect, as appropriate, including but not limited to:  encryption, firewalls, and password protections.
  • We periodically test our security procedures to ensure personnel and technical compliance.
  • We disclose your identifiable Personal Information to others only in accordance with this Privacy Policy or as otherwise permitted by law.
  • We disclose the minimum amount of Personal Information as necessary for the particular purpose in compliance with applicable law.

We may charge for various products and/or services within the Site. In that case, we use third-party services for payment processing (e.g. payment processors such as WooCommerce and SalesForce). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their own privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. PCI-DSS requirements help ensure the secure handling of payment information.  To learn more about how our commerce partners manage the privacy of information in conjunction with these e-commerce transactions, please see their privacy policy located on their purchase pages.

Although we make good faith efforts to store the Personal Information we collect in a secure operating environment that is not accessible to unauthorized users, we cannot guarantee 100% complete security.

HOW DOES COMPANY COMPLY WITH APPLICABLE PRIVACY LAWS IN COLLECTING PERSONAL INFORMATION?

Personal Information may be processed by Company in the country where it was collected as well as other countries (including the United States) where laws regarding processing of Personal Information may be less stringent. Please note that Personal Information gathered online from the Sites or submitted by you will be transmitted, stored, and processed in the United States of America.  By submitting your Personal Information to Company, you expressly consent to the collection, transmittal, storage, and processing of your Personal Information according to this Privacy Policy.  

DOES COMPANY USE COOKIES TO COLLECT PERSONAL INFORMATION ON THE SITE?

The Site may utilize a standard technology called a “cookie” to collect information about how the Site is used.  A “cookie” is a small text file placed on your hard drive by our web page server.  These cookies do not collect Personal Information, only Aggregate Information. 

Your browser is probably set to accept cookies.  However, if you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies.  If you choose to have your browser refuse cookies, it is possible that some areas of our Site or the Services will not function properly when you view them. 

We do not combine Aggregate Information collected through cookies with other Personal Information to determine who you are or your e-mail or IP address.  The Site can access the Aggregate Information only from a cookie sent by the Site.  We cannot access other cookies sent by other website or the information contained in those other websites.  Additionally, we cannot learn your email or IP address through the use of a cookie.  

We use cookies to track usage of the Site and the Services and further customize your experience when you are visiting the Site or using the Services.  By tracking usage, we can best determine what features of the Site and the Services best serve the users.  Without cookies, the features would “forget” items that may be stored. The session information used by the Site is deleted when your browser is closed. 

When you visit the Site, we automatically collect Aggregate Information about your visit.  We can tell the type of computer, browser, and web service that you are using. We also know the date, time, and pages that you visit on the Site Collecting this information helps us design the Site and the Services to enhance your experience during access. We may use Aggregate Information for internal purposes, such as providing targeted content to make the Site or the Services more useful to our visitors.  The gathering of this Aggregate Information may be accomplished by the use of cookies.  In particular, Company may collect an IP Address from all visitors to the Site. An IP Address is a number that is automatically assigned to your computer when you use the Internet.  We use IP addresses to help diagnose problems with our server, administer our Site, analyze trends, track users’ movement on the Site, gather broad demographic information for aggregate use in order for us to improve the Site, and deliver customized, personalized content.  IP addresses, however, are not linked to Personal Information.  We also may collect your device information if you ask for technical assistance from our customer support, and we will use such device information to trouble shoot problems with your device and connectivity to or use of video streaming or other content on the Site. 

We do provide third parties with De-Identified Information or Aggregate Information about our users, as more fully set forth in this Privacy Policy.  However, other websites linked to the Site also may send cookies; however we do not control such activities. 

If you are accessing the Sites from outside the United States, you will be prompted to consent to the collection of information via a cookie before full access will be granted. You will only be asked to opt-in upon your initial visit to those portions of the Site only. By clicking “I accept”, you consent to the collection of information via a cookie. However, if you decline, you may not be able to view or access all page or feature of the Sites (such as the check out for your shopping cart from our online Shop) and your browser may not work properly or your ability to use certain Site features will be impacted. 

Company also may use a unique assigned number located with the Site’s URL to determine each web site from which you navigated to get to the Site.  While this number may not be apparent to you, it does not contain your Personal Information.

We also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients.  This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

HOW DOES COMPANY USE PERSONAL INFORMATION? 

Your privacy is important to us.  We will use the Personal Information provided by you in accordance with good commercial practice and applicable law.  If you provide us with your e-mail address (or have done so in the past), we will send notifications, newsletters, or e-mail confirmations to you for the stated purposes of collecting such email address.  Your email will be used for notifications or newsletters only. Company does not share your public email address with others in its public forums.

Company collects your Personal Information at a variety of points, including when you place an order (which may require you to provide personal information, including a credit card number), request services, or take part in other activities on the Sites.  For example, we often ask for your Personal Information when you are conferring with one of our customer support technicians or purchasing a product/service.  During these interactions, we will collect Personal Information relevant to your transacting with Company, such as your name, phone number, mailing address, e-mail address, shipping address, and credit card information, along with information about the Company products or services selected by you.  We use this information for billing purposes and to fill your orders.  If we have trouble processing an order, we will use this information to contact you.  When you submit a request, you will be provided with an option to opt-in to receiving promotional information on our products and services. We will not use your Personal Information for any purpose other than what you have intended it.  Please be aware that, if you prefer not to provide us with your Personal Information, since such information may be necessary for us to provide certain services, we may not be able to, or may choose not to, make such services available to you. By providing Personal Information using the Site or the Services, you warrant to Company that your Personal Information is reliable for its intended uses, accurate, complete and correct, and that you will promptly notify use if such Personal Information is no longer current or correct. 

We also may use your Personal Information collected via the Site and each Android or Apple App connected to the Site in the performance of all Services in order to provide, maintain and improve our Services as well as to develop new products and services to be offered as part of the Services.  For example, we use Personal Information to analyze data, to improve our product algorithms and databases and to tune our outputs based on a particular individual’s patterns of usage of our Services. 

With respect to particular topics found on the Site, Company uses Personal Information submitted by you for the following purposes:

  • LIVE STREAM – Your email address is required to answer technical issues
  • JOBS – Applying online for jobs requires submission of your gender, name, address, email, phone, employment and education history, and resume, and such information is used by Company’s human resources department in order to process your employment request.
  • NEWSLETTER – Your email address is required in order to provide our newsletters directly to you. 
  • SHOP – Our merchandise shopping cart requires your name, address, email, phone, and credit card information.  This Personal Information will be used to process your purchase (including payment) and deliver the ordered products/services to you. 
  • SOCIAL MEDIA – If you wish to participate in the social media sites linked to the Sites (such as Facebook, Twitter, Instagram, YouTube, and Google +), we will be given your social media user account name as well as access and viewing of your social media account and postings.  

DOES COMPANY SHARE YOUR PERSONAL INFORMATION WITH OTHERS? 

As a general policy, we may share Personal Information internally in the fulfillment of the Services offered on or using the Sites.  We do not share, sell, or trade Personal information with other third parties without permission from the user.  However, we may provide your Personal Information to third parties directly involved in the operation, performance, support, hosting and/or maintenance of the Site or the Services and each product or service offered on the Site, including without limitation, our web site designers, hosts, service providers, technical consultants, payment processors and business partners. We use credit card or payment processing companies to bill you for any purchased items. Any Personal Information, however, will be used by such organizations only to perform their functions and/or to provide services in support of the Site or the Services, and as otherwise permitted by law or approved by you in accordance with this Privacy Policy.  Aggregate Information or De-Identified Information may at times be shared with Company’s business partners and other third parties.

We reserve the right to assign or transfer your Personal Information to any successor in interest to our organization associated with the Site or the Services by merger, reorganization, sale of all or substantially all of our assets or equity interests or operation of law.  We also may divulge Personal Information if such information is required for us to comply with any valid legal process, such as a subpoena, search warrant, statute or court order, or if we reasonably believe that you have commit unlawful acts or acts that may endanger the health or safety of another user or of the general public.  You will be notified via email and/or a prominent notice on the Sites of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Behavioral Advertising. We may also use third-party vendors, such as Google Analytics, to advertise to our users online. These third-party vendors may display Company’s product and service advertisements on other websites based on your Internet usage. More specifically, these vendors may use first-party cookies, third-party cookies and other tracking technologies, including, but not limited to, Google Analytics, Hotjar, Facebook Pixel, Facebook Custom Audience, Facebook Connect, Google Adwords, and others, together to inform, optimize and serve ads based on your past visits to the Site or another site affiliated with Company’s products or services. You can opt-out of Google Analytics for Display Advertising by using Google’s Ads Settings.

DO I HAVE THE CHOICE TO OPT-IN OR OPT-OUT OF ANY USES OF MY PERSONAL INFORMATION? 

Company provides its Site users with an easy means to opt-in and/or decline receiving notifications, newsletters or offers by email.   While we work hard to use and disclose our users’ Personal Information only for the purposes identified above, you can choose not to provide Personal Information or limit the Personal Information obtained by us as follows:

  • You may have your contact information removed from our marketing lists to inform users of new or relevant products, services and special offers by clicking on the unsubscribe link in any communication received from us, or by emailing us at info@passagepreparation.com.
  • You may limit the collection of “cookies” through your browser settings. However, this may disable our ability to provide you with the most relevant products or information regarding the Site and/or Services.
  • You may limit the ability of Google Analytics to track your online activity, as outlined in the “Behavioral Advertising” section above.

With respect to any Personal Information that is sensitive in nature, we will require you to “opt-in” to having such Personal Information used or shared by Company. 

Please note that there is no automated decision-making that is made on a solely algorithmic basis with respect to your Personal Information. 

With respect to transactional messages, Company will send required notifications via email and/or mail in order to inform you as to the status of your orders or requests.  This service is used for messages that are important for the performance of the Services.  When you make such orders or requests we require an email and/or mail address for completion of the transaction and such address will be used for these communications.  In order to stop receiving these notifications, please contact our customer support at the email, mailing address and/or phone numbers shown in “Contact Us” tabs of the Site.

If Company makes available public forums on the Site you may have an opportunity to interact with other Site visitors in order to share knowledge and news or participate in social media postings or community activities. Since participation in such forums is voluntary, you control what Personal Information may be disclosed to others. In order to avoid your email address or other Personal Information from being gathered and used by others for unsolicited, inappropriate, or harmful purposes, Company advises that you should be cautious about posting your email address or phone number or other personal information in any public forums, and you do so at your own discretion and risk. Company is not responsible and shall not be held liable for information and Personal Information posted in the public forums.  

CAN I MAKE CORRECTIONS OR REVOKE CONSENT TO PERSONAL INFORMATION COLLECTED ONLINE?

Company carefully maintains our customer database in an effort to keep your Personal Information accurate for the purposes for which it is used.  It is your right to be able to update your Personal Information as needed.  It also is your right to view your Personal Information and access an overview of how it is processed by Company.  You can correct out-of-date information, update information, remove information, delete your Personal Information, or review any information previously provided to Company by contacting our Privacy Officer at the Contact Address below.  We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to Company’s internal reporting, processing and retention policies and all applicable legal obligations.

NOTICE OF PRIVACY RIGHTS TO CALIFORNIA RESIDENTS

If you are a resident of the state of California, the following rights are available to you under the California Consumer Privacy Act.

Right to access. You have the right to request that we disclose the categories of personal information collected, the categories of sources from which personal information is collected, the business or commercial purpose for collection, the categories of third parties with which we share personal information, and the specific pieces of personal information that we have about you. You also have the right to request that we provide your personal information to you in a readily useable format.

Right to request deletion. You have the right to request that we delete personal information that we collected from you. Note, however, that certain requests to delete personal information may be denied if we are required or authorized to retain the information as a matter of law, the information is necessary for detecting security incidents, exercising free speech, protecting or defending against legal claims, or for internal uses reasonably aligned with consumer expectations, including, but not limited to, to provide a customer requested product or service. Historical transactional records cannot be deleted.

Right to non-discrimination. You have the right not to receive discriminatory treatment by Company for exercising these privacy rights. We do not offer financial incentives related to the provision of data.

Authorized agent. You have the right to designate an authorized agent to make these requests on your behalf. To exercise any of these rights, please e-mail us at info@passagepreparation.com. To protect your privacy, you will be required to provide authenticating information prior to making changes or gaining access to your information. We will respond to inquiries, requests to review, and change requests to personal information within forty-five (45) days.

Sales of Personal Information. We do not sell your personal information.

Opt-Out Policy. Company has adopted a policy of not sharing your personal information with our affiliates for their direct marketing purposes if you request that we do not do so (the “Opt-Out Policy”). You may make such a request by sending us an e-mail at info@passageprepation.com. When contacting us, please indicate your name, address, e-mail address, and what personal information you do not want us to share with our affiliates for their direct marketing purposes. Please note that there is no charge for controlling the sharing of your personal information or for processing this request.

Notice of Financial Incentive.  This Notice of Financial Incentive includes an explanation of financial incentives we may offer California residents when they provide us with Personal Information. Those incentives are reasonably related to the information’s value, as permitted by the CCPA. The material aspects of any financial incentive will be explained and described when you sign up. Your participation in these programs is optional. If you choose to participate, you may withdraw at any time by contacting us at info@passagepreparation.com. 

The financial incentives offered by Company from time to time in exchange for Personal Information are commonly percentage/promotional discount codes to be applied to a single purchase (typically in exchange for an email address or for joining a member rewards program). The discounts may result in a range of savings to the consumer, depending on the details of the purchase.

Incentives, including percentage/promotional discounts, are not directly tied to, or exclusively based upon, a set value of any individual element of consumer data, but are reasonably based in good faith on the following considerations:

  • Some consumers first experience our brand online and offering an incentive provides a unique opportunity for them to explore our products.
  • Some of our marketing and advertising activities are done online and email communications are a key part of reaching existing and potential consumers in a manner which they both expect and that allows for them to exercise choices about how or whether or not to be contacted.
  • Discounts may also be affected by factors such as performance targets, geographic location, seasonality, and market trends.

INTERNATIONAL VISITORS AND DATA TRANSFERS

The Site is hosted in the United States and is intended for United States visitors. If you are accessing the Site from the EU or other regions with laws governing data collection and use that may differ from the laws of the United States, please note that you are transferring your personal data to the United States and by providing your personal data you consent to that transfer. When we transfer personal data from other countries, including to the United States, we use a variety of legal mechanisms to help ensure your data is appropriately protected.

Your European Privacy Rights:

If you reside or otherwise find yourself in the European Union (“EU”) and the European Economic Area (“EEA”), Company is committed to processing your personal data lawfully and facilitating the exercise of your rights granted by the General Data Protection Regulation (“GDPR”) and its implementing national laws.

Legal basis for data collection and use. We only collect and use personal information when there is a fair and legal basis for its collection and use and/or when you have consented to our collection. For example, we collect personal information because it is necessary to complete or carry out a user-request, including a user-requested order for products or services, to meet our legitimate interests to send marketing materials or to comply with legal obligations. All other collection and use of information is based on your consent.

Privacy rights under the European regulation. Data subjects located in the EU and the EEA have the following legal rights under applicable law with respect to the personal information processed by Company:

  • To withdraw consent at any time, if we are processing your personal information on the basis of consent;
  • To access the information that Company has about you;
  • To request that Company rectify or erase your information;
  • To request that Company restrict the way it uses your information;
  • To object to the way Company uses your information;
  • To ask Company to transfer information to someone else; and
  • To lodge a complaint with a data protection authority in the EU.

Company’s ability to comply with requests may be limited by applicable law or our legitimate interests. To request to exercise one of these rights, please contact us at info@passagepreparation.com.  In order to fulfill this request, we may require that you provide us detailed information to validate your identity and specify your request. We will respond to and fulfill your request in a timely manner, usually within thirty (30) days after receiving your request. If for any reason we need to extend this period of time, we will contact you. If you are not satisfied with our response, you have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of the alleged infringement.

Other International Users

If you are visiting the Site from outside of the United States, your connection may be made through and to servers located in the United States, your registration, entries and orders placed through the Site may be fully processed in and from the United States, and all information you provide may be processed and maintained in our web servers and internal systems located within the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to ensure that your privacy is protected. By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy. By using the Site, you authorize the export of personal information to the United States and its storage and use as specified above when you provide such information to us. This Privacy Policy and our legal obligations are subject to the laws of the State of Minnesota and the United States, regardless of the location of any user. Any claims or complaints must be filed exclusively in the courts of the United States in the State of Minnesota, County of Dakota.

WHO CAN I CONTACT AT COMPANY IF I HAVE QUESTIONS ABOUT THIS PRIVACY POLICY OR ANY CHALLENGES AS TO COMPLIANCE? 

For additional information pertaining to our Privacy Policy, please contact us at the following address  (“Contact Address”): 

By Mail: Privacy Officer

Learners Edge, LLC

2805 Dodd Road, Suite 200

Eagan, MN 55121

You can also send an email to info@passagepreparation.com. Please do not include personal or other sensitive information in your e-mail correspondence.

DOES COMPANY COLLECT PERSONAL INFORMATION FROM CHILDREN? 

The Site and Services are not designed for children, and Company is concerned about the safety of children and their use of the Internet.  Therefore, in accordance with the U.S. Children’s Online Privacy Protection Act of 1998, we do not knowingly request or solicit personally identifiable information from anyone under the age of 13 without prior verifiable parental consent.  In the event that we receive actual knowledge that we have collected such Personal Information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is reasonably practical. 

WHAT ABOUT PRIVACY ON INTERNET WEBSITES LINKED TO THE SITE? 

You should be aware that other Internet websites to which you hyperlink from the Site may contain privacy statements that differ from our Privacy Policy.  Company encourages you to read and understand such privacy policies and terms of use of any linked websites accessed by you.  If you decide to access such linked websites and/or provide any personal information to such linked websites, you do so entirely at your own risk. Company is not responsible for such provisions, and expressly disclaims any and all liability related to such provisions. 

WHAT ELSE SHOULD I KNOW ABOUT COMPANY’S PRIVACY POLICY?

No transmission of data over the Internet is guaranteed to be completely secure.  It may be possible for third parties not under the control of Company to intercept or access transmissions or private communications unlawfully.  If you choose to visit the Site or use the Services, your visit and any dispute over privacy is subject to this Privacy Policy, including but not limited to limitations of damages and application of the law of the State of Minnesota and the laws, regulations, ordinances, and treaties of the United States of America. 

WHAT CONSTITUTES MY ACCEPTANCE OF THIS PRIVACY POLICY?

By using the Site or the Services and/or voluntarily submitting your Personal Information, you expressly consent to the use and disclosure of information, including but not limited to Personal Information, as described in this Privacy Policy. Your consent will be required separately (and not bundled) each time that you submit Personal Information. 

WHAT IS THE EFFECTIVE DATE OF THIS PRIVACY POLICY AND HOW CAN CHANGES BE MADE? 

This Privacy Policy has been adopted with the recognition that Internet technologies are rapidly evolving, and that underlying business models are still not established.  Accordingly, Company expressly reserves the right to modify the terms of this Privacy Policy at any time and will mark new versions with a corresponding effective date. We recommend you review this Privacy Policy frequently. If we make material changes to this Privacy Policy, we may notify you here or by means of a notice on our home page. Your continued use of the Site or Services constitutes your agreement to our then-current Privacy Policy. 

This Privacy Policy was last modified on September 28, 2022.