Who We Are and What This Policy Covers

Updated 2 March 2019 - Replaced LifterLMS with LearnDash LMS

[force_bullets] We are the team behind myroadtocollege.com, (hereafter referred to as MRTC),  a college prep company which helps you prepare and package your student for college success. The privacy of our visitors is of extreme importance to us and is guided by the following philosophy:

  • We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
  • We store personal information for only as long as we have a reason to keep it.
  • We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
  • We help protect you from overreaching government demands for your personal information.
  • We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles. This policy applies to information that we collect about you when you use the services at MRTC and it outlines the types of personal information received and collected by our websites, how that information is used, and what choices you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better. We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:

Basic Account Information: We ask for basic information like your name, email address, and password in order to set up your account on MRTC.

Transaction and Billing Information: If you buy something from us–a subscription to a course or a live class – you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.

Contact Forms: All information you enter in contact forms or is converted to an email and sent to the administrators of MRTC.

Content Information: Depending on the Services you use, you may also provide us with information about you in draft and published content (such as for your website). For example, if you write a blog post that includes biographic information about you, we will have that information, and so will anyone with access to the Internet if you choose to publish the post publicly. This might be obvious to you…but it’s not to everyone!

Communications With Us: You may also provide us information when you respond to surveys, communicate with our user support team about a question, or post a question about your site in our public forums.

Comments: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Information We Collect Automatically

We also collect some information automatically:

Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services–for example, when you create or make changes to your account on MRTC.

Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (when, for example, you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.

Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. MRTC uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads.

How And Why We Use Information

Purposes for Using Information

We use information about you as mentioned above and for the purposes listed below:

♠ To provide our Services

♠ To further develop and improve our Services–for example by adding new features that we think our users will enjoy or will help them to create and manage their websites more efficiently;

♠ To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;

♠ To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition–for example, we may analyze how many individuals purchased a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;

♠ To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of MRTC and others, which may result in us declining a transaction or the use of our Services;

♠ To communicate with you, for example through an email, about offers and promotions offered by MRTC and others we think will be of interest to you, solicit your feedback, or keep you up to date on MRTC and our products; and

♠ To personalize your experience using our Services, provide content recommendations, target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time), and serve relevant advertisements.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account–for example, in order to enable access to our website on your device or charge you for a paid plan; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or

(5) You have given us your consent–for example before we place certain cookies on your device and access and analyze them later on.

Sharing Information

How We Share Information

We do not sell our users’ private personal information.

We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.

Beasley College Prep: If you desire additional services from our partner company Beasley College Prep (BCP), we will share the information needed for BCP and its partners and affiliates to service your needs. This is primarily in conjunction with personalized coaching and intensive prep.

Third Party Vendors and Processors: We may share information about you with third party vendors or processors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to share information with them. For more information on these vendors and processors see the Third Party Processors section below.

Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.

To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of MRTC , third parties, or the public at large.

Business Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that MRTC goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.

With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so.

Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may share a hashed version of your email address to facilitate customized ad campaigns on other platforms.

Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.

How Long We Keep Information

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it–which are described in the section above on How and Why We Use Information–and we are not legally required to continue to keep it.

For example, we keep the web server logs that record information about a visitor to one of MRTC websites, such as the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to MRTC websites and investigate issues if something goes wrong on one of our websites.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services–for example, paid, premium themes–may not be accessible.

Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
Set Your Browser to Reject Cookies: At this time, MRTC does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using MRTC websites, with the drawback that certain features of MRTC websites may not function properly without the aid of cookies.

Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services, you can request your account to be closed by contacting us via email. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above–for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

  • Request access to your personal data;
  • Request correction or deletion of your personal data;
  • Object to our use and processing of your personal data;
  • Request that we limit our use and processing of your personal data; and
  • Request portability of your personal data.

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us.

EU individuals also have the right to make a complaint to a government supervisory authority.

Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these affiliate sites.

Third Party Processors

Third party processors are other services that MRTC uses to function and operate as a business. Following are the links to the third party processors used by MRTC :

Backup Buddy

Backup Buddy provides backups of our entire site on an occasional basis and stores the backup on the MRTC server and may copy it to 3rd party servers. Archives can include, but are not limited to, file and database assets, including hashed passwords, 3rd party data, uploads and user information.

Backups are stored for around 2 weeks on a 3rd party server based on disk space available. Backup zip files are stored with hashed file names to prevent filename guessing and directory browsing is disabled.

Backup destinations may be sent to any of these 3rd party destination servers at the discretion of MRTC admin:

LearnDash LMS

When you purchase from us, we’ll ask you to provide email address. We’ll use this information for purposes, such as, to:

  • Send you information about your account and order
  • Create your account for our LMS
  • If you register a free account then we will store your email address.

We store information about you for as long as your account exists. We store

  • course progress, including completion status, quiz scores, assignments and/or essay submissions (if applicable).
  • comments on courses, lessons, topics, assignments, and essays if you choose to leave them.

Members of our team have access to the information you provide us.  Purchases are handled through WooCommerce

Calendarize.it

Calendarize.it is a plugin that provides all of our live event scheduling and ticketing interface.  For more information about their policy, please see https://calendarize.it/privacy-policy/

Facebook

Facebook is a social network and advertising platform. MRTC uses Facebook to create the MY ROAD TO COLLEGE facebook page. For more information about how Facebook uses your data see their privacy policy at https://www.facebook.com/policy.php

PayPal

PayPal is a credit card and online payments processing. During ecommerce transactions your name, email address, and billing address will be sent to PayPal to validate your purchases and prevent against fraud. For more information about how PayPal uses this data see their privacy policy at https://www.paypal.com/us/webapps/mpp/ua/useragreement-full.

Stripe

Stripe is a credit card payment processor. During ecommerce transactions your name, email address, and billing address will be sent to Stripe to validate your purchases and prevent against fraud. For more information about how Stripe uses this data see their privacy policy at https://stripe.com/us/privacy.

Note: MRTC has turned off the saved credit card feature so your credit card is not saved for future use.

WooCommerce

WooCommerce provides our shopping cart and payment processing and is integrated with both our online courses provided by LifterLMS, and our calendar events provided by Calendarize.it.  The WooCommerce privacy policy is provided here: https://woocommerce.com/privacy-policy/

During the checkout process we track the following:

  • Products you’ve viewed: we’ll use this to, for example, show you products you’ve recently viewed
  • Location, IP address and browser type: we’ll use this for purposes like estimating taxes and shipping
  • Shipping address: we’ll ask you to enter this so we can, for instance, estimate shipping before you place an order, and send you the order!

We’ll also use cookies to keep track of cart contents while you’re browsing our site.

When you purchase from us, we’ll ask you to provide information including your name, billing address, shipping address, email address, phone number, credit card/payment details and optional account information like username and password. We’ll use this information for purposes, such as, to:

  • Send you information about your account and order
  • Respond to your requests, including refunds and complaints
  • Process payments and prevent fraud
  • Set up your account for our store
  • Comply with any legal obligations we have, such as calculating taxes
  • Improve our store offerings
  • Send you marketing messages, if you choose to receive them

Since creating an account is required to purchase from MRTC, we will store your name, address, email and phone number, which will be used to populate the checkout for future orders.

We generally store information about you for as long as we need the information for the purposes for which we collect and use it, and we are not legally required to continue to keep it. For example, we will store order information for 2-3 years for tax and accounting purposes. This includes your name, email address and billing and shipping addresses.

We will also store comments or reviews, if you choose to leave them.

Who on our team has access

Members of our team have access to the information you provide us. For example, both Administrators and Shop Managers can access:

  • Order information like what was purchased, when it was purchased and where it should be sent, and
  • Customer information like your name, email address, and billing and shipping information.

Our team members have access to this information to help fulfill orders, process refunds and support you.

Payments

We accept payments through Paypal and Stripe – see the sections above.  The information shared with a payment provide includes everything needed to process payments including:

  • Name
  • Email
  • Address
  • Phone
  • City/State/Zip
  • Unique payment identifier
  • Payment provider identifier

Google ReCAPTCHA

We use google ReCAPTCHA service to make sure that users logging in to our site are humans and not automated bots programmed to steal or otherwise compromise our site.  For more information on how ReCAPTCHA works please see https://www.google.com/recaptcha/intro/v3beta.html

Google’s privacy policies are listed here: https://policies.google.com/privacy?hl=en

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us.

Creative Commons Sharealike License

Portions of this document have been forked from the Automattic Privacy Policy made available under a Creative Commons Sharealike license.