Section 1 

PURPOSE 

Protecting privacy and any private information collected from our users is of utmost importance to us. Protecting any personal information and ensuring the safety and security of our programs and staff, our students and their families are a priority to us. Each time a user visits our website or subscribes to any of our services they are subjecting themselves to our privacy policy every time. 

Section 2 

INFORMATION FROM USERS 

a. Collection of Personal Information. We do not collect personal information unless it is provided to us voluntarily. There may be times when it is required to provide certain personal information when a person elects to use some of the items on our website or social media such as (1) registering to be a user, (2) send a request for more information, or (3) submitting credit card or payment information. 

b. Use of Personal Information. The collection of information is to communicate regarding information a person has requested, provide proper receipting, setup registration, and to provide additional information of our current or future activities. The collection of information may also be used for but not limited to the following purposes: (1) to monitor the effectiveness of the website, learning tools and applications; or improve the content of the website, learning tools and applications, or the layout and design; (2) to monitor, analyze, and describe usage patterns and performance of the users and our website, learning tools and applications, including aggregate metrics such as total number of visitors, traffic, and demographic patterns; (3) to provide an efficient user experience; (4) to conduct system administration and system troubleshooting and to diagnose or fix technology problems; (5) to enforce the terms of use or other policies or agreements. 

c. Sharing Information with Third Parties. We do not sell, lease or publish any information a person provides. We may disclose personal information without notice, if required to do so by law or in the good faith belief that such information is necessary to: (1) conform to the edicts of the law or comply with legal process that served on Propel LLC./ConnectEd or its site, (2) protect and defend the rights or property of Propel LLC./ConnectEd, and/or (3) act under exigent circumstances to protect the safety of other subscribers of Propel LLC./ConnectEd or the public. When we use a third party payment vendor they only have access to the information provided to them for payment purposes and do not share or publish that information to anyone else. We will make reasonable efforts to provide notice to our users before producing their personal information in response to law enforcement requests unless (1) we are prohibited by law or court order from doing so, (2) we have reason to believe the user’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (3) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact). 

d. Opt-Out of Disclosure of Personal Information. A person may opt out of anything they have subscribed to on our website or social media at any time by unsubscribing or with express verbal or written communication of their desire to unsubscribe. We will discontinue further contact once a person opts out unless they expressly state the desire to subscribe again. No personal information will ever be shared or communicated after unsubscribing. Any user also has the right to object to the processing of your personal data for direct marketing purposes. 

e. Children Under the Age of 18. We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to provide us with their personal information without verifiable parent or guardian consent. In the event we learn that we collected personal information from anyone under the age of 18, and do not have a parent or guardian’s consent, we will delete that information as quickly as possible. We encourage parents to supervise their child or student’s use of our website, learning tools and applications. We may collect analytics data (which does not contain personal information) from a child’s use of the website, learning tools and applications in order to offer and develop the services we provide, and we may collect information about a child such as age and nickname from the parent for the use of the website, learning tools and applications and the creation of the child’s user profile. We strive to keep the level of information collected from your child to a minimum, and in no event do we collect more information than what is required to use our website, learning tools and applications. 

f. Payment Information. To protect you against fraud, unauthorized transactions (such as money laundering), claims and other liabilities, we only collect the order details which enable us to match each user to the payments he makes. We may collect credit card information or allow our third party payment vendor to collect information for the purpose of collecting fees from users on the Website. We do not have access to the payment information that you provide to our third party payment vendor and this information is subject to the privacy policy of the third party payment vendor. For more information regarding what payment information our third party payment vendor collects and how it uses this information, please see their privacy policy. 

g. Retention. Data related to personal information or analytics will be retained while it is necessary for the user to have access to the website, learning tools and applications. We will retain user information for as long as is reasonably necessary in relation to the purposes for which this data was collected, which may include maintaining this information beyond when the user ceases to use the website, learning tools and applications. 

h. Storage. We are an international company with locations and servers operating throughout the United States as well as India. In order to provide and operate the website, learning tools and applications, we may send and store the users personal information outside of the country where the users reside or are located, to the United States. The collection and use of the users personal information is subject to the United States’ laws related to privacy and use of personal data and information. These laws may be less protective than those applicable to the users country of residence. By accepting the terms of this privacy policy, the user acknowledges, agrees and consents to the transfer to and processing of personal information on servers located outside of the country where the user resides, including to the United States, where laws may be different and less protective than those in the user’s country. 

g. Protection of Information. We act with caution and take the steps we believe to be commercially reasonable physical, electronic, and procedural safeguards to protect personal information. We cannot guarantee the security of personal information since there is no security system which is impenetrable and “perfect security” does not exist on the Internet. In the creation of any user accounts, all users may be asked to choose a password that is not easy to guess, and does not use words that would be readily recognizable. The user is responsible for maintaining the confidentiality of passwords and account information and we strongly suggest that the user does not disclose passwords or user account information to any other person who is not involved with the user account. Please report any suspected compromise of password or account information immediately to Propel LLC./ConnectEd. 

h. Links To Third-Party Content. The website, learning tools and applications may contain features or links to websites and services provided by third parties. Any information that is provided on third-party websites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our website, learning tools and applications. We are not responsible for the content or privacy and security practices and policies of third-party websites or services to which links or access are provided through the website, learning tools and applications. We encourage all users to learn about third parties’ privacy and security policies before providing them with information. 

i. Monitoring. Propel LLC./ConnectEd has an ethical responsibility and will maintain practices to protect against predators and inappropriate language or behavior online. Any messaging or comments that come to the attention of Propel LLC./ConnectEd that are deemed inappropriate, predatory, or harmful will be immediately removed. 

Section 3 

USE OF DATA COLLECTED 

a. Log File Information. We may collect log file information that is automatically reported by a user’s device each time our services are accessed. Our servers may automatically record certain information that the web browser sends whenever someone visits any website. These server logs may include information such as web request, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other similar information which constitutes personal information but not information that is confidential or private as to identifying information. 

b. Mobile Analytics. We may use mobile analytics software and various backend systems to analyze certain information regarding the use of our services such as page views, and transaction-related information that may constitute personal information but not information that is confidential or private as to identifying information. This information is stored in an anonymous manner; however, our third-party tracking partners may store certain information, such as page views, in a manner that can be associated to specific users and may constitute personal information but not information that is confidential or private as to identifying information. 

c. Cookies. We may use persistent and session cookies on our website. A persistent cookie remains on the hard drive even after the browser is closed and may be used by the user’s browser on subsequent visits to the website. Persistent cookies can be removed by following the web browser’s directions. A session cookie is temporary and disappears after the browser is closed. The user can reset their web browser to refuse all cookies or to indicate when a cookie is being sent. Any changes to cookie settings on a web browser may cause some changes in the ability to use the Website. 

d. IP Address. We do not collect specific information about the location from any user’s device, but we may log the IP address, which can be used to approximate location. The use of IP addresses are only for activities necessary to maintain or analyze the website, learning tools and applications; perform network communications; authenticate users or personalize content; protect the security or integrity of the user and the website, learning tools and applications; ensure legal or regulatory compliance; or fulfill a request of a user. 

Section 4 

MERGERS AND ACQUISITIONS 

a. We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of our products, services, assets and/or businesses. Personal information of users, such as email addresses, and other user information related to the website, learning tools and applications, may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such personal information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. 

Section 5 

CHANGES TO POLICY 

We reserve the right to change this policy from time to time as we see fit. We will do our best to communicate any significant changes to the policy especially as it involves collecting or use of information provided by constituents. The continued use of the website or other social media outlets belonging to Propel LLC./ConnectEd constitutes the acknowledgement of the privacy policy and the agreement to abide by the terms of privacy policy.