Privacy Policy

Last Updated:  October 26, 2020

240 Tutoring and its related web-based application and Services (“Website”) are owned and operated by 240 Tutoring, Inc. (“240 Tutoring”, “our”, “us”, “we”), a Texas corporation with its principal place of business in Houston, Texas. 240 Tutoring has adopted this Privacy Policy (“Privacy Policy”) to inform you that it collects Personal Information when you use the Website and to explain how this information is used. You should contact 240 Tutoring directly with any questions or concerns.

240 TUTORING MAY CHANGE, MODIFY, AMEND, SUSPEND, TERMINATE, OR REPLACE THIS PRIVACY POLICY FROM TIME TO TIME AND WITHIN ITS SOLE AND ABSOLUTE DISCRETION. IN THE EVENT 240 TUTORING CHANGES, MODIFIES, AMENDS, OR REPLACES THIS PRIVACY POLICY, THE “LAST UPDATED” DATE, LOCATED ABOVE, WILL CHANGE.  YOUR CONTINUED USE OF THE WEBSITE AFTER A CHANGE IN THE EFFECTIVE DATE OF THIS PRIVACY POLICY CONSTITUTES YOUR MANIFESTATION OF ASSENT TO THE CHANGE, MODIFICATION, AMENDMENT, OR REPLACEMENT CONTAINED WITHIN.

Policy Review. This Privacy Policy is reviewed at least once annually to ensure it remains accurate, complete, and in compliance with applicable laws and regulations. Any updates resulting from the annual review will be reflected by an updated “Last Updated” date at the top of this Privacy Policy.

Definitions.

California Consumer Privacy Act (“CCPA”) means the California statute intended to enhance privacy rights and consumer protection for residents of California, United States.Personal Information under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.Customer(s) means individuals that enroll in a Subscription to receive access to the Services.Educational Preparation Programs (“EPPs”) means organizations, institutions, and other entities that may enroll in a Subscription to provide Customers with access to the Services.Services means a variety of resources, including without limitation, practice tests, study guides, exams, course materials, assessments, applications, and other information.Subscription means the plan through which Customers and/or EPPs sign up for Services.User(s) means individuals who visit and browse the Website, as well as access the Services, including Customers and EPPs.You/Your means User(s).

Types of Personal Information We Collect

240 Tutoring collects the following Personal Information from all Users who contact 240 Tutoring seeking more information:

• First name;
• Last name;
• Email address;
• Any other information that you upload or submit to the Website directly or indirectly.

240 Tutoring collects the following Personal Information from all Customers:

• First name;
• Last name;
• Email address;
• Information related to the Customer’s progress through the Services;
• Any other information that you upload or submit to the Website directly or indirectly.

240 Tutoring collects the following Personal Information from all EPPs:

• Institution, organization, or business name;
• Main contact’s first name;
• Main contact’s name;
• Email address;
• Physical address;
• Any other information that you upload or submit to the Website directly or indirectly.

In addition, 240 Tutoring collects the following Personal Information from all Users:

• Your geolocation;
• Your IP address;
• Your browser and search engine information;
• Your device information;
• Your visitor history;
• Your usage of the Website, including, without limitation, any links or items clicked or pages viewed and statistics;
• Information stored in cookies, pixel tags, or web beacons;
• Analytical data from Google Analytics and/or Google AdSense; and
• Any other additional analytic data that you voluntarily submit to the Website.

Sources of Personal Information Collection.

240 Tutoring may collect this Personal Information from you through various channels, including, but not limited to, through your voluntary submission of information to the Website, through requests initiated by you through the Website, through the collection and analysis of information concerning your computer and browsing activities, through the use of cookies, web beacons, pixel tags, Google Analytics, Google AdSense, and through other sources permitted by law.

Cookies & Similar Technologies

The Website also utilizes Cookies.  Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the Cookie. We use Cookies and similar technologies to enable our systems to recognize your browser and to provide certain features.  We also use “web beacons” to help deliver Cookies and gather usage and performance data. The Website may also include Cookies, web beacons, and other similar technologies from third-party service providers.

You have a variety of tools available to control the data collected by Cookies, web beacons, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use Cookies and to withdraw your consent by clearing or blocking Cookies. You can also stop 240 Tutoring from placing Cookies (other than those required for the Website to function) on your device by referencing the instructions below.

The table below sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:

Type of Cookie	Description	Managing Settings
Required Cookies (Strictly Necessary)	Required – or strictly necessary – cookies enable you to navigate the Website and use its features.	Because required cookies are essential to operate the Website there is no option to opt out of these cookies.
Functional Cookies (Non-Strictly Necessary)	Functional – or non-strictly necessary cookies – allow us to remember information you have entered or choices you make, and provide enhanced, more personal features. We use Google Analytics to help us analyze how our Website is used, including the number of visitors, where the website visitors have come from, and the pages they visit.  This information is used by us to improve our Website.	To manage the use of functional cookies on the Website, please consult your individual browser settings for cookies.  Note that opting out may impact the functionality you receive when using our Website. To learn more about safeguarding your data for websites using Google Analytics, visit here.  To opt of our data collection by Google Analytics, you can download and install a Google Analytics opt-out browser add-on here. To learn more about how Google Analytics Cookie Usage on Website visit here. To learn more about how [COMPANY] uses cookies and how you may opt out, visit here. To learn more about how [COMPANY] uses cookies and how you may opt out, visit here. You can also adjust your individual browser settings relating to cookies by visiting these pages: Google ChromeInternet ExplorerMicrosoft EdgeMozilla FirefoxSafari (Desktop)Safari (Mobile)Android Browser For other browsers not listed, please consult the documentation that your browser manufacturer provides.
Targeting or Advertising Cookies (Non-Strictly Necessary)	We use Google Webmaster Tools and Google Analytics to log when users view specific pages or take specific actions on or getting to the Website. Google Analytics specifically allows us to provide targeted advertising in the future. We may also use Google AdWords as a tool to acquire relevant new clients who are looking for our service and Google AdSense to show our clients other relevant advertising that may assist them while they are using our site.	To learn more about How Google uses cookies targeted in advertising, visit here.  To adjust your Google Ad Settings and learn how to opt out of particular targeted advertising visit here or the Network Advertising Initiative opt-out page here.

Purpose for Collecting Your Personal Information

The purpose for us collecting your Personal Information is to provide you with the 240 Tutoring Services.

How 240 Tutoring Uses Your Personal Information

We use your Personal Information based upon the legal basis of Users’ consent to provide you with the Website, process any requests made by you, communicate with you, identify and fix problems with the Website, and update you regarding changes to the Website and the 240 Tutoring and third-party services offered through the Website.

By using the Website, you further authorize the following specific uses of your Personal Information:

• Enable your use of the Website and its associated Services;
• Improve algorithms;
• Measure service usage;
• Develop new features;
• Contact and communicate with you, whether through email, telephone, text message, and/or messages within the Website;
• Customize and/or tailor the Website and your user experience, which may include targeted selection and display of third-party advertisements within the Website;
• Aggregate certain information that does not include your personal information and disclose it for analysis, demographic profiling and/or targeted advertising;
• Advertise products and Services of 240 Tutoring;
• Transmit and process your information and actions within the Website;
• Provide statistical information, and include you in the same, where applicable;
• Provide you with technical service and support, including updates;
• Provide you with information concerning 240 Tutoring’s benefits or Services;
• Store, archive, retrieve, and make copies of your user generated content;
• Understand your needs and requests;
• Communicate promotions or other offers;
• Process payments;
• Prevent and detect illegal activities or violations of your Terms of Use;
• Combine your personal and personally identifiable information with information from other 240 Tutoring applications and/or services; and
• Facilitate your use of the Website and upgrades/replacements to the Website.

Sharing of Your Personal Information.

240 Tutoring Shares Your Personal Information with third parties in the following circumstances:

• Where 240 Tutoring has obtained your consent;
• Where sharing or disclosure of your Personal Information is necessary to provide you with the Website, and/or associated services (We may share your personal or personally identifiable information with trusted third-parties who assist us in operating the Website, providing the associated services, and conducting our business);
• Where sharing or disclosure of your Personal Information is necessary pursuant to a campaign with Facebook and/or Instagram;
• Where sharing or disclosure of your Personal Information is necessary to share personal or personally identifiable information with 240 Tutoring’s parents, subsidiaries, successors, assigns, licensees, affiliates, or business partners;
• Where 240 Tutoring has been purchased by a third party;
• Where sharing or disclosure of your Personal Information is necessary to respond to requests by government authorities;
• Where your Personal Information is demanded by a court order or subpoena;
• Where sharing or disclosure of your Personal Information is needed to protect the employees, independent contractors, officers, directors, members, users, or owners/shareholders of 240 Tutoring;
• Where sharing or disclosure of your Personal Information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty; and
• Where 240 Tutoring is otherwise legally obligated to share your personal or personally identifiable information.

Notification of Changes to User Information. When a User updates, corrects, or otherwise modifies their Personal Information, 240 Tutoring will take commercially reasonable steps to share such changes withrelevant third parties and vendors responsible for processing that User’s Personal Information on behalf of 240 Tutoring. This includes, but is not limited to, the third-party service providers identified in this Privacy Policy. 240 Tutoring will make reasonable efforts to ensure that updated Personal Information is reflected across all systems and services where such information is processed; however, 240 Tutoring cannot guarantee that third-party service providers will update their records in any specific timeframe. Users are encouraged to contact such third parties directly to confirm that their information has been updated.

240 Tutoring Shares Customer Information with EPPs

Customers – who access the Services through a Subscription purchased by an EPP or who utilize a pre-negotiated EPP discount – agree that their Personal Information will be shared with EPPs.  When an EPP enters into a Subscription, 240 Tutoring will share Customers’ Personal Information with their EPP pursuant to providing the Services.  For instance, as a Customer progresses through practice tests, study guides, exams, course materials, assessments, applications, and other Personal Information provided through the Services, such Personal Information will be shared with the EPPs.

240 Tutoring Shares Your Personal Information With the Following Third-Parties:

• Google, including Google Analytics (privacy policy here);
• Hubspot (privacy policy here);
• Stripe (privacy policy here);
• Amazon Web Services (AWS) (privacy policy here);
• Sendgrid (privacy policy here);

No Liability Third-Party Services and Third-Party Links

The third-party service providers affiliated with 240 Tutoring have their own independent privacy policies governing the use of your Personal Information pursuant to the GDPR and CCPA and we encourage you to read those privacy policies carefully.  You understand that even if 240 Tutoring deletes your Personal Information that it may still be available in a third-party service provider’s database.  240 Tutoring has no responsibility or liability for the Personal Information collection, use, or storage activities of the third-party services providers used by 240 Tutoring to provide you with the services associated with the Website.

240 Tutoring may outsource or subcontract some of our technical support, tracking and reporting functions, database management functions, and other services to third parties. We may share information from or about you with them so that they can perform their services as long as they comply with this Privacy Policy, the GDPR, and the CCPA.  You understand and agree that 240 Tutoring will not be held responsible for any third-party communications sent by entities that 240 Tutoring does not own or control.  You are encouraged to review any third-party privacy policies before utilizing any such third-party service.

240 Tutoring may include or offer third-party products or services on the Website and provide third-party links to the same.  These third-party websites have separate and independent privacy policies.  240 Tutoring has no responsibility or liability for the content and activities of such third parties or their websites.  We encourage you to read carefully the privacy policies of all such third-party websites.  We seek to protect the integrity of the Website and therefore welcome any feedback about any such third-party websites.

Personal Information Transfer and Storage.

Your Personal Information is stored and processed on computers and servers in the United States and through your use of the Website, you consent to the processing and storage of your Personal Information and personally identifiable information.  You understand that your Personal Information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction.  If you are located outside the United States and choose to provide Personal Information to us, please note that we transfer your Personal Information to the United States and process it here, and that we may store portions of your Personal Information in the United States.

Users understand and agree that if they provide 240 Tutoring with Personal Information that it is stored indefinitely, unless the User contacts 240 Tutoring to have their Personal Information removed from storage.  As specified above, even if 240 Tutoring deletes your Personal Information from its own serves, it may still be available in a third-party service provider’s database.  You should consult with those third-parties in the event you would like Personal Information deleted therefrom.

Personal Information Security.

240 Tutoring uses standard technology to store and help prevent against the unauthorized disclosure of your Personal Information. Though we undertake commercially reasonable efforts to protect your information, no website, software, or online service is completely safe. Accordingly, you provide all such information at your own risk.

In order to protect your Personal Information, 240 Tutoring uses specific security measures, such Secure Sockets Layer (SSL) protocol, which encrypts information you input at 128-bit strength. This is denoted in most web browsers by a small padlock appearing on the bottom bar of the window and the address of the window changing from https:// to https://, indicating a secure connection.

California Users’ Rights.

Under the CCPA, California Users have the following rights:

• Right to Know About Personal Information Collected, Disclosed, or Sold: You have the right to request that 240 Tutoring disclose what Personal Information of yours it collects, uses, discloses, and sells over the past 12 months.
• Right to Request Deletion of Personal Information:  You have the right to request that 240 Tutoring delete any of your Personal Information that we collected from you.
• Right to Opt-Out of the Sale of Personal Information:  240 Tutoring does not sell Personal Information.  You have the right to opt-out of 240 Tutoring’s sale of your Personal Information.
• Right to Non-Discrimination for Exercising CCPA Rights: 240 Tutoring shall not discriminate against California Users for exercising their rights under the CCPA.

To exercise your rights under the CCPA – or have an authorized agent exercise your rights under the CCPA on your behalf – please submit either a “Request to Know Personal Information” or a “Request to Delete Personal Information” to 240 Tutoring by contacting 240 Tutoring at helpdesk@240tutoring.com.  240 Tutoring will verify this request by manual review and response.

Verification of Authorized Agents and Representatives. If an agent, representative, or other authorized third party submits a request to access, modify, or delete a User’s Personal Information on that User’s behalf, 240 Tutoring will verify the identity and authority of the requesting party before disclosing or acting upon any Personal Information. Verification may include, but is not limited to, requiring a signed written authorization from the User, a valid power of attorney, or other documentation sufficient to confirm the agent’s or representative’s identity and authority to act on the User’s behalf. 240 Tutoring reserves the right to deny any request where the identity or authority of the agent or representative cannot be reasonably verified.

Under California’s “Shine the Light Law,” California residents have the right to receive information that identifies any third-party companies or individuals that 240 Tutoring has shared your Personal Information with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting 240 Tutoring at the address below.

Purchase or Sale of the Website or Other Assets.

240 Tutoring may purchase other businesses or sell components of its business, including, but not limited to, the Website. In the event 240 Tutoring purchases another business or sells any component of its business, your Personal Information will continue to be used consistent with the terms of this Privacy Policy.

How To Stop 240 Tutoring from collecting your Personal Information.

You can stop 240 Tutoring from collecting your Personal Information and/or have your Personal Information deleted by contacting 240 Tutoring at helpdesk@240tutoring.com and request that 240 Tutoring stop collecting and/or delete your Personal Information.  Additionally, you can adjust your web browser settings to limit or turn off Cookies or other tracking techniques, or you can cease use of the Website.  You may contact 240 Tutoring with any requests regarding your Personal Information. Response Timeframe for User Requests. Upon receiving a verifiable request from a User to access, modify, or delete their Personal Information, 240 Tutoring will acknowledge receipt of the request within ten (10) business days and will complete the requested action within forty-five (45) calendar days of receiving the request. If additional time is reasonably necessary due to the complexity or volume of requests, 240 Tutoring may extend this period by an additional forty-five (45) calendar days, provided that 240 Tutoring notifies the User of the extension and the reason for it within the initial forty-five (45) day period.

Consequences of Withdrawing Consent. Users have the right to withdraw their consent to the collection, use, and processing of their Personal Information at any time by contacting 240 Tutoring at helpdesk@www.240tutoring.com. Please be aware that withdrawing your consent may result in the following consequences:

• You may no longer be able to access or use certain features of the Website or Services, including, without limitation, study guides, practice tests, exams, and other course materials;
• Your Subscription may be suspended or terminated, and you may forfeit access to any remaining Services under your current Subscription;
• 240 Tutoring may be unable to process your requests, respond to inquiries, or provide customer support related to your account;
• If you are a Customer accessing Services through an EPP , your EPP may no longer be able to track your progress or provide related support; and
• Certain non-personally identifiable or aggregated data derived from your prior use of the Website may be retained in accordance with applicable law.

Withdrawing consent does not affect the lawfulness of any processing conducted prior to the withdrawal. 240 Tutoring will not discriminate against any User for exercising their right to withdraw consent.

Your Obligations.

When using the Website, you are obligated to inform 240 Tutoring of any changes to your Personal Information.

Children’s Online Privacy Protection Policy.

The Website is not intended for or directed to users under the age of 18, and 240 Tutoring does not knowingly or intentionally collect Personal Information from children under the age of 13 or other minors. Where appropriate, 240 Tutoring takes reasonable measures to determine that users are adults of legal age and to inform minors not to submit such information to the Website or in response to advertisements. If you are concerned that Personal Information may have been inadvertently provided to or collected by 240 Tutoring, please contact us immediately so appropriate steps may be taken to remove such information from 240 Tutoring’s database.

Contact and Notices

All questions, concerns, notices, and requests regarding this Privacy Policy may be submitted to 240 Tutoring at:

240 Tutoring, Inc.

Scott Rozell134 Vintage Park Blvd. Ste. A, Box 537

Houston, TX 77070

helpdesk@240tutoring.com