Privacy & Cookie Notice

Last Updated: December 2021

Shorelight, LLC and its affiliates (“Shorelight”, “we” or “us”) are committed to protecting your privacy. We have prepared this Privacy & Cookie Notice (“Notice”) to describe our practices regarding the Personal Information that may be collected from users of the Shorelight.com website and Shorelight’s university websites which are maintained by Shorelight (the “Services”), how we may use the information, with whom we may share it, and the rights and choices available to you regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices. “Personal Information” is any information about an identified or identifiable person. By using our Services, you acknowledge that we will process your Personal Information in accordance with this Notice.

Please read this Notice carefully to understand our policies. If you do not agree with the data practices described in this Notice, we advise you not to use our website or services. BY CONTINUING TO USE THESE SERVICES AND/OR SUBMITTING YOUR PERSONAL INFORMATION, YOU CERTIFY THAT YOU MEET THE AGE AND OTHER ELIGIBILITY REQUIREMENTS FOR THE SERVICE AS SET FORTH IN THIS NOTICE AS WELL AS THE TERMS AND CONDITIONS.

In some cases, we receive Personal Information pertaining to students from educational institutions that we maintain on the institutions’ behalf, such as information about class rosters and data from students who use our learning platforms at the direction of an educational agency or institution (“School Data”). School Data is only used by us to support our customers and provide the services requested by the institution’s administrators and course instructors. We handle School Data as a processor for our customers, subject to applicable privacy and data protection laws, including the Family and Educational Rights Privacy Act (FERPA) in the U.S. In such cases, the processing of your Personal Information will be covered by their privacy policies. The processing of the Personal Information constituting School Data is not addressed in this Notice. If you wish to obtain information or exercise any of your rights with respect to your Personal Information that constitutes School Data, please read the privacy policies of the relevant educational institution carefully and/or contact the institution directly. Although we may place contextual advertising on pages used by students, we do not use any Personal Information in School Data for targeted advertising.

Please note that you may have additional privacy rights under the laws of your jurisdiction. Shorelight respects those rights. Where the provisions in this Notice conflict with applicable law, we will only process your Personal Information in compliance with applicable laws. You may contact our Privacy Office at any time via email to privacy@shorelight.com.

1.   Personal Information We Collect

Personal Information you provide to us

In many cases, we collect Personal Information directly from you, such as if you are a student, a counselor or a representative of an institution. When you interact with our Service, we may collect Personal Information from you in the following ways:

• Account and contact information, such as your name, email address, country of residence, phone number, degree type, start date of your degree, citizenship and any other information you share when you create an account on our Services or otherwise access our Services.

• Content you post on the Services, for example when you participate in blogs, discussions groups and similar forums.

• Academic and career information, such as the content of your CV and other information on your education and professional background you provide to us on our Services, for example if you request us to provide academic support, career development services, student visa support services and interview, resume and application support services.

• Visiting our tradeshows, we may collect your name and contact details (such as email address) when you visit our tradeshows.

• Responses to surveys, that we may ask you to complete for research purposes or to help direct our activities.

• Communication data, such as any information you share when you contact us, for example by email, on our Services or by phone, including the content of your message and your contact information.

• Purchase/Tuition details, such as tuition details or of a purchase you make in relation to our Services, including the amount, currency, bank details and method of payment.

Personal Data we collect from Third Parties

• From schools and other third party providers. We may collect additional information about you from your school or university, such as information about the classes you are teaching, and from third party data suppliers who enhance our files and help us better understand our customers.

• From publicly available sources. We may also collect publicly available information from social media sites, such as Twitter, Facebook or LinkedIn.

Personal Information we automatically collect from your use of the Services

• Usage information. We automatically collect details on how you use the Services. For example, we collect information such as site analytics, about your session and your activity.

• Device, browser and other data, such as your internet protocol address (i.e., IP address), internet service provider or carrier name, and, if you access the Services from a mobile application, your unique mobile device ID number and information collected through Tracking Technologies (defined below), such as pixel tags, and other technologies.

We use cookies and other technological tools to automatically collect information about your computer and your use of our Services. Please read the “Cookie Notice” Section for more information on how we use cookies and other Tracking Technologies. We may also collect or infer information about you, such as your engagement with our Services and with others in your classes. In most cases we use this information in an anonymized or aggregated manner, but we treat this information as Personal Information when it is associated with other data elements that allow us to identify you.

2. Use of Your Data

To the extent we collect Personal Information from you, as described in this Notice, we use such information for the purposes listed below. If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland we will only process your Personal Information when relying on a valid “legal basis”, as listed below. Note, that in certain circumstances detailed below, we will process your Personal Information on more than one legal basis depending on the specific purpose for which we are using your Personal Information.

Note: If you do not provide us with Personal Information, we may not be able to offer you the Services described here-in. We also may use your Personal Information in other ways for which we provide specific notice at the time of collection.

3. Disclosure of Your Personal Information

We will share your Personal Information with third parties, including as follows:

• Affiliates. We may share your Personal Information with our parent company, subsidiaries, joint ventures, and other companies under a common control (collectively, “Affiliates”), to use consistent with this Notice.

• Third Party Service Providers. We work with a range of third parties who provide services on our behalf, that may have access to or process your Personal Information as part of providing those services to us.  For example, we may share data with service providers who host our websites or provide email services on our behalf. Service providers are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions.

• Business Partners. We collaborate closely with other groups, companies and educational institutions to provide the Services, for example with partners such as universities, student placement advisors, and other service providers. In these cases, we may share your name, contact information and other details including Personal Information

• Authorities and Others. We may disclose Personal Information about you if we believe such disclosure is necessary to (a) comply with laws or to respond to lawful requests and legal process; or (b) protect or defend the rights, safety, or property of us, users of the Services, or any person including to enforce our agreements, policies, and terms of use, or (c) in an emergency to protect the personal safety of any person.

• Business Transferees. We may also share Personal Information about you in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

We may share Personal Information about you with others for their own uses whenever you consent to or direct such sharing.  Please note that we may also use and disclose information about you that is not personally identifiable. For example, we may publish reports or create products that contain de-identified, aggregated or statistical data, or share such data with third parties in a manner that does not identify particular users. These reports and products do not contain any information that would enable the recipient to contact, locate or identify you.

Cookie Notice

Shorelight may place small files, known as “cookies,” onto your computer to collect Personal Information about how you use our Service.  “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. The cookie will help us, or a third party, to recognize your device the next time you visit. Web beacons, pixels or other similar files can do the same thing. We refer to them as “Tracking Technologies”. We, or third parties we collaborate with, may use Tracking Technologies to automatically collect log files and other information about your usage of, and the devices you use to access, the Site and the Service. For example, we may use Tracking Technologies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety.

We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services. Where required by applicable law, we obtain consent before using non-essential cookies. Most web browsers are set to accept cookies by default. If you prefer, you can typically remove and reject cookies from our Services with your browser settings. If you remove or reject our cookies, it will affect how our Services work for you. In addition, you may not be presented with advertising that reflects the way that you use our Services. You find out how to make these changes to your browser at this site: www.allaboutcookies.org/manage-cookies/.

Even if you are only browsing the Service, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Services) is automatically collected. This information will be collected every time you access the Services and it will be used for the purposes outlined in this Notice.

“WEB BEACONS” are digital images we use to log information on our Services and in our emails. We use web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We also use web beacons to tell if you open or act on our emails. You may render some web beacons unusable by rejecting their associated cookies. If you choose to decline such cookies, certain features of the Services that placed the cookie may not function properly or at all as a result.

“FLASH COOKIES” are used to store your preferences such as volume control or to display content based upon what you view on our websites to personalize your visit. Third party partners who provide certain features on our websites, such as videos, may place Flash cookies on your device. They may use Flash cookies to track your web browsing activity and to display personalized advertising. Flash cookies are different from other cookies because of the amount of, type of, and way in which data is stored. Cookie management tools provided by your browser usually will not remove Flash cookies. To learn more about Flash cookies, who has placed Flash cookies on your device, and how to manage privacy and storage settings for Flash cookies click here. We do not control the privacy practices of the third parties who place or track Flash cookies and this Notice does not cover their practices. You should visit the privacy policies of companies who place Flash cookies to understand their practices.

ANALYTICS. We use analytics services to help analyze how users use the Services. These analytic services use cookies and scripts to collect and store information such as how users interact with our applications, errors users encounter when using our applications, device identifiers, how often users visit our website, what pages they visit, and what other sites they used prior to coming to Services. One of the analytics providers we use to collect information to improve our Services is Google Analytics. You may exercise choices regarding the use of cookies from Google Analytics by going to tools.google.com/dlpage/gaoptout or downloading Google Analytics Opt-out Browser Add-on.

Shorelight Cookie Listing

You can also find out additional information about how to manage or disable cookies at usa.gov.

4. Your Rights and Choices Regarding Your Personal Information

We offer you choices regarding the collection, use, and sharing of your Personal Information. When you receive promotional communications from us, you may “opt-out” by following the unsubscribe instructions provided in emails you receive from us. To revoke permissions that you may have given to send text messages, text STOP in response to any message. Please be aware that if you unsubscribe or opt-out of texts, we process an opt-out request only for that specific email address or telephone number. So, if you have more than one email address or if you have changed your email address, your opt-out request may not be processed for any email that you have not identified in your opt-out request. You can also CLICK HERE for help opting-out of receiving marketing communications from us. Please include your name, address and the email address(es) and/or phone number(s) that you want to opt-out.

If you believe you have opted out, but continue to receive emails from us, please contact us as set out under the “Contact Information” section in this Notice, and we will endeavor to resolve the issue.

Please note that even if you opt-out of commercial emails, we may still need to contact you with important information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations.

Most web browsers are set to accept cookies by default. If you prefer, you can typically remove and reject cookies from our Services with your browser settings, as described in the “Cookie Notice” section hereof. If you remove or reject our cookies, it will affect how our Services work for you. You may opt out of tracking of certain information collected by Google Analytics on the Services, as discussed above. While we and others give you the choices described in this Notice, there are many ways web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism.

Your European Privacy Rights

If you are located in the EEA, Switzerland or the UK, you have the additional rights described below:

• You may request access to the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

• You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

If you make a request, we have one month to respond to you (unless we notify you that we will be exercising our rights under the law for an extension). If you would like to exercise any of these rights, please contact us:

• Telephone Number: 857-317-2001

• Shorelight Privacy Email: privacy@shorelight.com

Before meeting your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may have valid legal reasons to refuse your request and will inform you if that is the case.

5. Security of Your Personal Information

We are committed to ensuring that your Personal Information is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate technical and organizational measures to safeguard and secure the personal data we process. No system is 100% secure, and therefore we can’t provide assurance with 100% certainty that your Personal Information will be secure. Be mindful that you are responsible for protecting your username and password and that it is not to be shared with others. If, despite all our efforts, a data breach does occur, we will take steps to limit the damage. If you have any questions about security on our Services, you can contact us as set out in the “Contact Information” section below.

6. Changes to this Privacy & Cookie Notice

From time to time, we may update this Notice to reflect new or different privacy practices. We will place a notice online when we make material changes to the Notice. Changes to this Notice will become effective when those changes are posted to the Services or otherwise notified to you as required by applicable law. We encourage you to periodically check the Services for updates. Your continued use of the Services subsequent to any such notified change to this Notice constitutes your acceptance of the change subject to the contents of the specific notification. We indicate the effective date of this Notice (and any updates) at the top of the Notice.

7. Children

Our Services are not intended for use by or designed for children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have unknowingly collected any Personal Information from a child, please contact us as set out in the “Contact Information” section below.

8. Links to Third Party Websites

We may provide links to websites and services provided by third parties. We have no control over these websites and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Services and we encourage you to learn about third parties’ privacy and security policies before providing them with your Personal Information.

By using the Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third party websites.

9. Retention

We store all Personal Information for as long as necessary to fulfill the purposes set out in this Notice, or for as long as we are required to do so for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal or regulatory obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this Personal Information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this Personal Information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

10. International Data Transfers

Shorelight is based in the United States. If you provide us with your Personal Information when using the Services from the EEA, Switzerland or the UK or other regions of the world with laws governing data collection and use that may differ from USlaw, then please note that you are transferring your Personal Information outside of those regions to any country where we have facilities or in which we engage service providers, in particular the United States. If we transfer your Personal Information internationally, where required, we will ensure that relevant safeguards are in place to afford adequate protection for your Personal Information and we will comply with applicable data protection laws, in particular by relying on an EU Commission adequacy decision or the EU Commission approved standard contractual clauses for the transfer of your Personal Information or a derogation if available. For more information about how we transfer Personal Information outside of the EEA, Switzerland or the UK, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us as specified in the “Contact Information” section below.

11. Contact Information

We welcome your comments or questions regarding this Privacy & Cookie Notice. Please e-mail us at privacy@shorelight.com or contact us at the following address:

Shorelight, LLC

2 Seaport Ln., Suite 500

Boston, MA 02110

Attn: Legal Department