Privacy Policy

Scholarus Learning values your privacy. This privacy policy describes how we collect information and practices regarding personal information when you visit our website or otherwise interact with us, online or in-person.

Scholarus Privacy Policy

Last Updated: January 24, 2023
Effective Date: January 24, 2023

Scholarus Learning (“Scholarus,” “we,” “our,” or “us”) values your privacy. This Privacy Policy (“Policy”) describes how Scholarus collects personal information and our information practices regarding personal information, when you visit our website at www.scholarus.com (the “Website”) or otherwise interact with us, online or offline (collectively our “Services”).

By using our Services (as defined below), you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms of Use, available at www.scholarus.com, including their applicable terms governing limitations on damages and the resolution of disputes.

Please note, depending on how you interact or engage with us we may provide you with other privacy notices with additional details about our information practices. For example, this Policy does not apply to job applicants and candidates who apply for employment with us, or to employees in the context of the employment relationship. Additionally, Scholarus’ collection and processing of personal information is largely on behalf of its customers. This Policy does not apply to the extent we process personal information as a service provider or processor on behalf of our customers. Our processing of our customers’ personal information is subject to the terms of our contracts with each customer, who is the business or controller of such personal information that we process on their behalf. You can reach out directly to the relevant customer for information about their privacy practices, which may differ from ours. 

If you are a California resident, please see Section 6 below titled “Your California Privacy Rights” for more information about your privacy rights under the California Consumer Privacy Act. 

Table of Contents

1.    Personal Information We Collect
2.    How We May Use Personal Information
3.    How We May Disclose Personal Information
4.    Cookies and Other Technologies
5.    Your Privacy Choices
6.    Your California Privacy Rights
7.    Children’s Information
8.    External Links and Features
9.    Security
10.    Changes to this Policy
11.    Contact Us

1. Personal Information We Collect

We collect personal information directly from you, automatically through your use of the Services, and from other sources described below. 

Personal Information We Collect Directly From You. While the personal information we collect varies depending upon your use of our Services and our interactions with you, in general, we may collect the following Personal Information directly from you:

• Identifiers. Such as name, phone number, and email address.
• Internet and Network Information. This includes your device information and usage data, as further discussed below.
• Employment-Related Information. Such as your position, title, and the company you work for, if you provide this information when you contact us.

Personal information We Collect Automatically. We and our providers may automatically collect personal information related to your use of our Website, including through the use of cookies, pixel tags, and other similar technologies. The personal information we may automatically collect includes:

• Device and Browsing Information. When you visit our Website, we may collect IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information.
• Activities and Usage. We also collect activity information related to your use of the Website, such as information about the pages visited and other activity and usage information.
• Location Information. We may also collect or derive location information about you, such as through your IP address.  

For more information about our use of cookies and other similar technologies, please see the “Cookies and Other Technologies” section below.

2. How We May Use Personal Information 

We collect personal information about you for the following purposes:

• Communicate With You. To respond to your inquiries, send you requested materials and newsletters, as well as information and materials regarding our Services and offerings, and otherwise communicate with you. We also use this information to send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
• Services and Support. To provide and operate our Services and to otherwise run our day-to-day operations.
• Analytics and Improvement. To better understand how users access and use the Website and for other research and analytical purposes, such as to evaluate and improve our Website, to develop our Services and its features, and for internal quality control and training purposes.
• Marketing and Promotions. For marketing and promotional purposes. For example, to send you information about our Services, such as newsletters and other marketing content, including information about Scholarus events and new offerings, as well as any other information that you sign up to receive.
• Security and Protection of Rights. To protect the Services and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use.
• Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
• Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures.
• General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.
  
  

3. How We May Disclose Personal Information

We may disclose the personal information we collect to the following categories of recipients:

• Affiliates, Subsidiaries, and Business Partners. We may disclose the personal information we collect to our corporate affiliates and subsidiaries. Scholarus also partners with other businesses to offer our products and Services, and we may disclose personal information to those business partners.
• Vendors. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting, marketing and marketing research providers, customer support, data storage, payment processing providers, data analytics providers, auditors, consultants and legal counsel.

We may also disclose your personal information in the following circumstances:

• To Operate Our Business. We may disclose personal information to our business partners, affiliates, service providers, and other vendors in order to operate our business and provide our Services.
• In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
• Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms of Use. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Other Disclosures. We may disclose personal information in other ways not described above that we notify you of or that we obtain your consent for.
  
  

4. Cookies and Other Technologies

“Cookies” are alphanumeric identifiers we transfer to your device’s hard drive through your web browser. Some cookies allow us to make it easier for you to navigate our Website, while others are used to support the security and performance of the Website. We use cookies, pixel tags, and other similar technologies to automatically collect personal information, as described above. We use this information to understand how you access, use, and interact with our Website and to assess, secure, protect, optimize, and improve the performance of our Website. The following provides more information about cookies and other technologies.

5. Your Privacy Choices

We make available several ways for you to manage your personal information, including preferences regarding cookies, whether you want to receive marketing and promotional emails from us, and choices regarding your account and profile information.

Cookie Settings. To prevent cookies from tracking your activity on our Website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Website who disable cookies will be able to browse the Website, but some features may not function.

Do-Not-Track. Currently, our Website does not recognize “Do-Not-Track” requests. 

Marketing Communications. You can opt out of receiving marketing emails from us by using the unsubscribe feature in any such email we send you. You can also log in to your account and change your marketing/communications preferences.

6. Your California Privacy Rights

This section of the Policy provides additional information for California residents and describes our information practices pursuant to the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020, and its implementing regulations (the “CCPA”). This section applies to “personal information” as defined in the CCPA, whether collected online or offline. This section does not address or apply to our handling of personal information that is exempt under the CCPA, such as publicly available information, deidentified information, or aggregated data.  

Retention of Personal Information. We retain your personal information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your personal information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information).

Your CCPA Rights. The CCPA provides California residents with certain rights regarding their personal information. Note that these rights only apply to personal information we collect and process under this Policy as a business or controller. For personal information we process on behalf of our customers, in our capacity as a service provider or processor, please submit your request directly to the relevant customer with whom you have a relationship, and we will provide reasonable assistance to that customer as necessary to enable them to respond to your requests to exercise your privacy rights. In general, California residents, including our customers’ employees who reside in California, have the following rights with respect to their personal information, subject to certain exceptions:

Right to Know/Access. With respect to the personal information we have collected about you, you have the right to request (subject to certain exemptions and exceptions):

• The categories or personal information we collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purposes for collecting, selling, or sharing personal information;
• The categories of third parties to whom we have disclosed personal information; and
• A copy of the specific pieces of personal information we have collected about you.

Right to Correct. You have the right to request that we correct inaccuracies in your personal information.

Right to Delete. Subject to certain exceptions, you have the right to request we delete personal information we have collected from you.

Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your personal information, as those terms are defined under the CCPA. We do not “sell” or “share” personal information as defined by the CCPA. We do not sell or share sensitive personal information, nor do we sell or share any Personal Information about individuals who we know are under sixteen (16) years old.

Right to Limit Use of Sensitive Personal Information. We do not engage in uses or disclosures of “sensitive personal information” that would trigger the right to limit use of sensitive personal information under the CCPA.

Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Exercising Your CCPA Rights. If you are a California resident and would like to exercise your CCPA rights, you may do so via any of the methods described below:

• Calling us at 1-888-212-3121
• Email us at info@scholarus.com

Verification. Before responding to your request, we must first verify your identity using the personal information you recently provided to us. You must provide us with your name, street address, city, state, zip code and an e-mail address or phone number. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Authorized Agent. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

7. Children’s Information

Our Services are not designed for children, and we do not knowingly collect personal information from children under the age of thirteen (13). If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us using the contact information below.

8. External Links and Features

Our Website and Services may contain links to third-party websites or features. Any access to and use of such linked websites or features is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those features.

9. Security

We have implemented safeguards that are intended to protect the personal information that we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

10. Changes to this Policy

The Policy is current as of the date set forth above. We may change, update, or modify this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here. If we make any changes to this Policy that materially affect our practices regarding our use of the personal information we previously collected, we will endeavor to provide you with notice, such as by posting prominent notice on our Website.

11. Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at info@scholarus.com.