Privacy Policy­

Last revised: April 14, 2022


This Privacy Policy (“Privacy Policy”) describes the types of information that LLC (“”, “we”, “us” and “our”) may collect or collect or collect information about you from you, or the types of information you may provide when you visit our websites and mobile applications (collectively, the “Sites”), and our practices in collecting, using, maintaining, protecting and disclosing that information. This Privacy Policy applies to information we collect on the Website and in emails, texts and other electronic messages between you and us or provided by third parties. We do not control other websites or resources to which we may link, and this Privacy Policy does not apply to information collected by any third party, including through any applications or content (including advertisements) that may link to or be accessible from the Site.

Because our services require us to collect some personal information, including payment information, we want you to have the information you need to make an informed decision about sharing that information with us.

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will process that information. This Privacy Policy may change from time to time. Section 13 (“Effective Date and Update of this Privacy Policy”) discusses procedures for future modifications or changes to this Privacy Policy.

Children Age 16 and Younger

Our website is not suitable for students aged 16 or under to register unless a school, parent or learning institution creates an account on behalf of the student. No one under the age of 17 may provide us with any personal information unless a parent provides data on behalf of the child (or a teacher provides data on behalf of a student). We do not knowingly collect personal information from children under the age of 17. If you are under the age of 17, please do not use or provide any information on this website. If we learn that we have collected or received personal information from a child under the age of 17, we will delete that information. If you believe that we may have any information from or about a child under the age of 17, please contact us at the address described in Section 14 (“Contact Information”).

Types Of Information We Collect

We collect several types of information from users of this website about users of this website, including the following:

This information can personally identify you, such as name, postal address, email address, telephone number, credit card number, and any other identifiers that can contact you online or offline (“Personal Information”);

about you but personally cannot identify you, such as your age, educational goals, educational level, career aspirations, and your interest in and use of various products, programs and services; and/or

About your internet connection and the device you use to access this website, such as usage details and IP address.

We collect this information: (i) directly from you when you provide it to us; (ii) automatically when you browse the Website; (iii) from third parties (e.g., our business partners).

Information You Provide to Us

The information we collect from you, including personal information, may include the following:

Information you provide by filling out a form on the website. For example, information provided when registering for login access and membership subscriptions, registering for our newsletter, searching or matching information requests with educational institutions;

Participate in promotions or contests; and when you report any problems with the Site;

Details of your transactions and order fulfillment through the Website. You may be required to provide payment information before placing a subscription order through the Site;

Records and copies of your communications with us when you send an email, contact our support or help desk, or initiate other communications with us;

your responses to surveys, which we may ask you to complete for research and service improvement;

general search queries you perform on the Website; and

Other information you may choose to provide to us. You may choose to provide or post information, including personal information, or transfer to other users of the Site or third parties (collectively, “User Content”) in designated areas of the Site. For example, we may offer chat rooms, public posting forums, one-to-one communication forums, or other similar features that allow you to provide User Content to communicate directly with other users, facilitators, instructors, sponsors, and so on.

Any User Content, including personal information contained in User Content, is available for public viewing. We discourage you from publicly posting your full name, phone number, street address, or other information that identifies you or allows strangers to find you or steal your identity. Please refer to the section of our Terms of Service titled “Misconduct by Our Administration/Users of the Site” for more information about the risks involved in sharing personal information.

Information We Automatically Collect

When you interact with the Site, we may use data collection technologies such as cookies, web beacons, web server log files, mobile analytics software or other tracking technologies to collect certain information about your device, browsing operations and patterns, including the following:

Information about your device and Internet connection, such as your IP address, operating system, device and software data (such as type, configuration, and unique identifiers), mobile operator, geographic location (GPS, Wi-Fi, or user-entered) and mobile phone number; and

Information about your interactions with the Site, including your navigation patterns, such as whether you clicked on our ads or our promotional content, the pages you visit on the Site, the videos you watched, which site you came from, the date and time stamp information you visited, and other online activities such as courses and course selections, reviews, ratings, payment history, communications, and other navigational information.

On the website you can watch educational videos or videos about us, educational institutions and other providers. By viewing video content, you agree that, for two years from the date of data collection, or to the extent permitted by applicable law, we may share your video viewing information with analytics providers, advertising partners, and third-party social networking sites, or obtain information about your viewing of videos from analytics providers, advertising partners, and third-party social networking sites.

While the information we collect through these tracking technologies is not always personally identifiable at the time of collection, we may combine such information with personally identifiable information, such as your name or email address. We may also use these technologies to collect information about your activities on our website and to send you advertisements about this website when you browse other websites. For more information about how we collect information about you from third parties, please see below. The information we collect helps us improve our website to provide a better, more personalized service. Please see Section 7 (“How We Use Your Information”) for more information about how we use the information we collect.

For more information about how we use cookies and other tracking technologies, please see Section 11 (“More Information about Cookies and Related Technologies”).

Information We Collect from Third Parties

We collect information from third parties about the operation of our Services. For example, we may give you the option to create an account and log in to the site using your account credentials through certain third-party social networking sites (“SNS”), such as Facebook. If you choose to register with an account you already have in SNS or use the Site, we may obtain your information from applicable SNS in accordance with your agreement with that SNS. The information we collect may depend on your privacy settings in applicable SNS, so please review their privacy and data practices.

We also collect and receive information about you from third parties, including websites that post our advertisements and offers, as well as other online and offline sources, such as identity verification services and consumer reporting agencies, which we may combine with other information you provide to us. We may supplement this information with information from other sources, including offline data, your browsing behavior on other websites, and interactions with our advertising.

Your friends may also provide us with information about you through our referral or sharing features. Your friend may provide your name and email address and ask us to send you information about our services.

How We Use Your Information

We use the information we collect about you or the information you provide to us in the following ways:

to provide you with the Website and Content;

to provide you with information, products or services that you have requested from us (e.g., to match your background with college and university admission requirements and/or preferred student background, to provide university search and matching services);

To provide you with notices about your membership and subscription;

to fulfill our obligations and enforce the rights arising from any contract you have entered into with us, such as determining whether you qualify for a free trial or teacher membership, billing and collections, etc.);

to promote our Service offerings to you and other users (for example, to send emails containing updates, such as new opportunities and other lists that may be of interest to you);

Promote products and services of partners that we believe are of interest to users (e.g., send promotional announcements, display advertisements on their behalf on the Website, etc.);

disclose to third parties at your request so that they can keep you informed of their products and services;

notify you of changes to the Site or the services we provide;

To provide you with information related to your website account;

Tailor the Site to your interests or location and enhance your overall experience (e.g., select content that may be of interest to you, provide local content, display relevant search results, provide recommendations for online courses and other courses, and personalize our services and marketing to better reflect your specific interests);

to respond to your inquiries and requests;

to allow you to participate in interactive features on our website;

When you provide information, we may describe it in any other way;

to achieve any other purpose you provide; and

Any other purpose with your consent.

Disclosure of Your Information

We may disclose information we collect from you or that you provide to us, as described below:

our subsidiaries and affiliates;

Disclosure to educational institutions at your request;

send to SNS at your request (for example, so that you can post recent activity on the website back to your social network account);

Contractors, service providers and other third parties that we use to support our business (e.g., web hosting providers, data analytics providers, etc.) and third parties related to processing or fulfilling your requests or queries (e.g., call centers, fulfillment services, etc.);

In the event of a merger, divestiture, reorganization, reorganization, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, the information we hold about you is an asset transferred; Disclosure to the buyer or other successor in the event of a merger, divestiture, reorganization, reorganization, dissolution or other assets;

Market their products or services to third parties at your request;

to fulfill the purpose for which you provided the information (for example, to refer your information to your friends when you use the “Refer a Friend” feature of the Site);

for any other purposes we disclose when you provide information; or

With your prior written consent, for any other purpose.

We may also disclose your information in the following circumstances:

comply with any court order, applicable law, legal process, rule or regulation, including responding to any governmental or regulatory request;

Cooperation with law enforcement;

Enforce or apply our Terms of Service and other agreements, including for billing and collection purposes; or

If we believe disclosure is necessary or appropriate to protect the rights, property, reputation or safety of, our employees, our customers or others (e.g., in relation to fraud protection, credit risk reduction, etc.).

Information we disclose to third parties pursuant to this Section 8 (“Disclosure of Your Information – in Our Privacy Policy”) may include your educational personal information, unless such disclosure is restricted by applicable law.

Once disclosed, your personal information may be processed in accordance with the recipient’s privacy policy. We may also disclose aggregated information about our users without restriction for any purpose not prohibited by law, which does not identify any particular individual. For more information, see Section 9 (“Your Choices”).

Your Choices
We value your privacy and strive to provide you with choices about the processing of personal information you provide to us. You can control your information in the following ways:
Provide information. If you are not satisfied with our ability to use and share that information as set forth in this Privacy Policy, you may choose not to provide us with your personal information at any time. Please note, however, that if you decide not to provide us with your information, you may not be able to access some of our products and services (for example, the school matching service or subscription service that you asked the school to contact you).
Opt out of receiving promotional emails from us. You may opt out of receiving marketing and promotional emails from us at any time by using the opt-out mechanism included in such emails (also known as “unsubscribe”) or by submitting your request to Refreshion. Please allow us to process your opt-out request within 15 business days. Also, please note that opting out of receiving promotional email communications will only affect our future communications. If we have provided your information to a third party before you change your preferences or update your information, you may need to contact the relevant third party directly to communicate your choices to them in accordance with their policies.
Reject browser cookies and other tracking technologies. If you do not want us to use browser cookies to track your information, you can adjust your browser settings to reject cookies. However, you should note that if you decide not to accept cookies, some areas of this website may not function properly.
Our Data Security Procedures

We have implemented security measures to help prevent loss, misuse and/or unauthorized alteration of information you provide to us or that we collect. We employ online and offline security methods, including firewalls, passwords, and restricted physical access to the servers where your information is stored.

The security of your information also depends on you. You are the only user who has the right to update your account unless you provide your login/password information to the other party. We will assume that anyone who has the login/password information required for your account is you, so please keep this information confidential and do not share it with anyone.

In order for you to easily access your user account, we have implemented technologies that enable us to identify you as a user account holder and provide you with direct access to your user account without requiring you to re-enter any password or other user ID when revisiting the Site. You can choose not to take advantage of this feature by unchecking the “Remember me” box when you log in to the website. Visit My Dashboard on the website to change the settings for your access to user accounts. You are responsible for maintaining the confidentiality of your account access information and for restricting your access to computers or devices that access our user accounts. Where possible, users of public or shared devices should sign out after each access is complete. If you sell or return your computer or device, you should log out and delete your user data, if applicable, before doing so. If you do not maintain the security of your password or device, or if you cannot log out or deactivate your device, subsequent users may be able to access your user account, including your personal information.

Unfortunately, there is no security system that guarantees 100% security. While we do our best to protect your personal information, we cannot guarantee the security of your information. Any transmission of your information is at your own risk. We are not responsible for circumventing any privacy settings or security measures contained on this website.

NAI opted out. Some of the third-party advertising companies we use may collect information about you through cookies and other technologies in connection with their behavioral advertising programs. For more information, see Section 11 (“More Information on Cookies and Related Technologies”). While we have no control over the programs, practices, or policies of such third-party advertising companies, the Network Advertising Initiative (NAI) maintains an opt-out tool that allows you to opt out of participating in the behavioral advertising programs of NAI member companies. To visit the NAI Opt-Out Tool and learn more about behavioral advertising, visit the NAI website:

Disclosure of your information to third parties. We do not share information with third parties other than service providers. From time to time, we may ask you for information on the Website and indicate that we may make it available to schools that appear to meet your interests. If you do not want us to share your personal information with schools or any other unaffiliated third parties for their promotional purposes, please do not ask us to share your contact information on our website.

Cancel your membership. You can cancel your membership at any time by visiting the My Dashboard page on our website and following the cancellation instructions under the “Change Subscription Settings” link. However, we will retain all information as necessary in order to provide you with the Services, including but not limited to the ability to reactivate your account at your request at a later date. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

More about Cookies and Related Technology

Cookies are small data files that are stored on your computer’s hard drive by your web browser. We or our business partners and service providers may send cookies when you visit this website or interact with one of our advertisements or other content. Cookies are stored on your computer or mobile device. In addition to storing your preferences and other information, cookies allow us to collect information about your interactions within the Site and/or with one of our advertisements. We use session cookies (which terminate when you close your browser) and persistent cookies (which remain on your computer until you manually delete them).

We may also track your movements, advertisements, and other content through the Site through web beacons (also known as pixel tags or transparent GIFs). When you visit a page, email or other content that contains a web beacon, the web beacon notifies us, our service providers or third-party business partners. Web beacons can be used for a variety of purposes, including helping us improve marketing communications by measuring responses to promotions and events.

We have established relationships with third-party advertising agencies that serve retargeting ads on our behalf on other websites to encourage you to return to this website. These advertising agencies are our service providers and may automatically collect information about your visits to the Site and our advertisements on other sites, including your IP address, date/time stamp information, your Internet Service Provider, and the browser you use to access the Site. They do this by using cookies, web beacons, and other technologies. Among other things, the information collected may be used to place our advertisements outside of this website.

If you would like to learn more about retargeting ads and to learn about your choices about such practices, including how to opt out of our retargeting through ad networks such as third-party advertisers, ad networks and ad servers that are members of the Network Advertising Association, please see Section 9 (“Your Choices”).

Transfer of Information

We may transfer your information outside the United States where we own facilities or engage third parties, such as payment processors, cloud services, or other IT and service providers.

Effective Date and Updates to This Privacy Policy

This Privacy Policy is valid and was last revised on the date indicated at the top of the Privacy Policy. We reserve the right to change this Privacy Policy at any time by posting an updated Privacy Policy. We recommend that you check this page frequently for updates and revisions, and update your email address when changes occur. If you provide us with an accurate and up-to-date email address, we will notify you by email of any material revisions to the Privacy Policy. You will need to click on “Accept the revised Privacy Policy” before you can continue to use this website. Unless you accept the revised Privacy Policy, you will not be able to continue to use the Site.

Contact Information

Your privacy is important to us. If you have questions about any of the provisions described above, please contact us at Refreshion. Alternatively, you may contact us at: Attention: Privacy & Legal Department, 100 View St, Suite 202, Mountain View, CA 94041.

Additional Notice for Singapore Consumers

This portion of our Privacy Policy applies to Singapore consumers only. Many visitors to our website are representatives of businesses seeking to interact with us as part of their jobs. This Notice does not apply to information that we collect through these business-to-business interactions.

How We Collect, Use, and Share Personal Information

Personal Information Collected on Singapore Consumers in the Last Twelve Months

We collect information from users as described in our Privacy Policy. “Personal Information” obtained in the last 12 months as defined in Singapore Civil Code§ 1798.140(o) includes the following:

Identifiers such as name, postal and email addresses, Internet Protocol (IP) addresses, unique personal identifiers, token identifiers and other contact information when you submit your name and contact information to sign up for login access and membership subscriptions or registrations to learn more about our products and services.

The following categories of personal information as described in Singapore Civil Code § 1798.80(e): (1) The personal information listed in the above points is used as an “identifier”; (2) Credit card number, debit card number or other payment information when you purchase a membership subscription or other products and services; (3) Identify, associate, describe other information capable of being directly or indirectly related to or reasonably linked to a particular consumer or household, as described herein.

Under Singapore or federal law, the following categories are protected by categorical characteristics: race, sex, age (40 years or older), citizenship, physical or mental disability (for test accommodation), veteran or military status.

Business information, such as records of products or services purchased, obtained or considered from us.

Internet or other similar information about web activity, including, but not limited to, browsing history, search history, and consumer interactions with websites, applications, or advertisements.

Geolocation data, such as physical location or movement.

Sensory data, such as audio, electronic, or visual information (typically, in the case of a test, students upload audio/video projects).

Information about current or past occupations or employment.

Private educational records (under the Family Educational Rights and Privacy Act (20 U.S.C Section 1232g, 34 C.F.R. Part 99) are directly related to students maintained by educational institutions or parties acting on their behalf, such as grades, transcripts, class lists, student schedules, student identification numbers, student financial information, or student disciplinary records.

Inferences drawn from other personal information, such as personal data that reflects personal preferences, characteristics, psychological trends, tendencies, behaviors, attitudes, intelligence, abilities, and talents.

For each of these categories, we obtain personal information from students and/or their parents, teachers, and educational institutions.

Please note that personal information does not include publicly available information from government records, de-identified or aggregated consumer information, and personal information that is protected by certain other industry-specific federal or Singapore regulations.

Our Use of Personal Information for Business Purposes in the Last Twelve Months

We use the personal information we collect (identified in each of the categories above) for the business purposes disclosed in the Privacy Policy. These business objectives include:

Audits and reports in connection with specific transactions and interactions, including online interactions with us or others on our behalf;

Detect, prevent and prosecute security incidents and malicious, deceptive, fraudulent or illegal activities;

Debugging to identify and fix errors in our systems;

Short-term, ephemeral use, including contextual customization of advertisements;

Providing services on behalf of us or on behalf of others, including maintaining or providing service accounts, providing customer service, executing transactions, verifying identity information, processing payments and other services;

Conduct in-house research to develop and demonstrate technology;

to carry out activities to verify, enhance and maintain the quality or safety of the services or equipment we may own, control or provide;

Administer exams, conduct business, and provide test takers with notification of results;

Provide information required for entrance examinations to higher education institutions such as universities;

Prepare statistics and analyse them to support our operations;

Provide students and teachers with information about our educational products and services;

Marketing and researching our exams;

Receiving and responding to inquiries;

provide educational materials related to our exams; and

Transcripts of college credits are provided.

Sharing of Personal Information in the Last Twelve Months

Disclosure of personal information of Singapore consumers for business purposes

Over the past twelve months, we have disclosed personal information identified in the categories above for the purpose of exempting activities only (as part of a business-to-business transaction, (ii) at your express request, or (iii) for our business purposes. For more information about the service providers with whom we share information, please refer to Section 8 (“Disclosure of Your Information – in Our Privacy Policy”).

When we disclose personal information for commercial purposes, we enter into contracts that describe the purposes and require the recipient to keep the personal information confidential and not to use it for any purpose other than the performance of the contract.

Personal information is not sold to Singapore consumers

We have not sold any of the personal information described in this Privacy Policy to third parties in the past twelve months, nor will we sell personal information.

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