Encoura, LLC and its affiliates (hereinafter “Encoura” or “we”) value the privacy of individuals who use our websites, app, and related services (collectively, our “Services”). This Privacy Notice explains how we collect, use, and share the information of US residents who use our Services (“Users,” “you,” or “your”). By using our Services, you agree to the collection, use, disclosure, and processing of your information as described by this Privacy Notice. Beyond this Notice, your use of our Services is also subject to our Terms of Use (https://encoura.org/terms-of-use/) and any additional agreements you may enter into with us.
We collect Personal Data from US residents and comply with the consumer privacy laws of California, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia (“US Privacy Law”). For the purposes of this Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:
This Privacy Notice provides the following information to US residents:
We may collect a variety of information about you or your devices from various sources. This section describes that information in general terms. You can find a more detailed category-by-category breakdown of the information we collect in the Categories of Non-Sensitive Personal Data and the Categories of Sensitive Personal Data sections below.
Registration Information. If you sign up for an account, register to use our Services, or sign up for emails or other updates, we may ask you for basic contact information, such as your Name, Email, and Phone Number. We may also collect certain demographic information when you register for our Services, including your Age, Gender, Interests, and race/ethnicity.
Communications. If you contact us directly, we may collect additional information from you. For example, when you reach out to our customer support team, we may ask for your name, email address, mailing address, phone number, or other contact information so that we can verify your identity and communicate with you. We may also store the contents of any message or attachments that you send to us, as well as any information you submit through any of our forms or questionnaires.
Events. If you register for an event that we host, whether in-person or online, we may collect relevant information like your name, phone number, and email address, as well as specific information relevant to the event for which you are registering.
User Content. We allow Users of our Services to share their own content with others. This may include posts, comments, reviews, or other User-generated content. Unless otherwise noted when creating such content, this information may be shared publicly through our Services.
Payment Information. If you make a purchase through our Services, your payment-related information, such as credit card or other financial information, may be collected by our third-party payment processor on our behalf.
Device Information. We may collect information about the devices and software you use to access our Services, such as your IP address, web browser type, operating system version, device identifiers, or similar information.
Usage Information. To help us understand how you use our Services and to help us improve them, we may collect data about your interactions with our Services. This includes information such as crash reports, session lengths and times, the pages or other content you view, and any searches you conduct on our site.
Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits.
Information We Receive from Sources Other than You. We may receive information about you from other sources, including from third parties that help us update, expand, and analyze our records, identify new customers, or detect or prevent fraud. We may also receive information about you from social media platforms, such as when you interact with us on those platforms or access our social media content. What information we receive from third parties is governed by the privacy settings, policies, and/or procedures of those third parties, and we encourage you to review them.
The table below outlines the non-sensitive categories of Personal Data Encoura collects about US residents, what we use that data for, and whether and how it is shared with third parties.
We collect Non-Sensitive Personal Data:
Category: Identifiers | |
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Examples and Purpose for Collection | Identifiers may contain the following: real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers. Regular business operations, legal requirements, performance of services, marketing and internal analytics • Service Providers, such as marketing and advertising agencies, data processors, and cloud service providers for regular business operations • Third parties or affiliates to enable colleges, universities, and other providers of education-related products and services to learn about and connect directly with students. |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We may share this information with advertising partners for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Processors, Affiliates, Other Users of our services, Business Partners, and Advertising Partners. We share Identifiers • Service Providers, such as marketing and advertising agencies, data processors, and cloud service providers for regular business operations • Public authorities/government bodies as required by applicable laws and regulations • Third parties or affiliates to enable colleges, universities, and other providers of education-related products and services to learn about and connect directly with students. • Cookie Operators to collect information about interactions with the Service or emails, including information about your browsing and activity behavior. |
Retention Period | Varies. We retain this data until the user requests to delete their account or according to our internal data retention schedule, which you can find here. |
Category: Personal Characteristics | |
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Examples and Purpose for Collection | Personal Characteristics may contain the following: race, gender, etc. Regular business operations, legal requirements, performance of services, marketing and internal analytics • Third parties or affiliates to enable colleges, universities, and other providers of education-related products and services to learn about and connect directly with students. |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We do not engage in targeted advertising or share this information for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Processors, Affiliates, Business Partners, and Other Users of our services. We share Personal Characteristics • Service Providers, such as External Marketing and Advertising Agencies, Data Processors, and Cloud Providers as needed for regular business operations. • Third Parties or Affiliates to enable colleges, universities, and other providers of Education-related Products and Services to learn about and connect directly with students. |
Retention Period | Varies. The data is accessible until the consumer requests to delete their account or according to our internal data retention schedule, which you can find here. |
Category: Commercial Data | |
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Examples and Purpose for Collection | Commercial Data may contain the following: products or services purchased, obtained or considered. Regular business operations, legal requirements, performance of services, marketing and internal analytics • Service Providers, such as marketing and advertising agencies, data processors, and cloud service providers for regular business operations |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We may share this information with advertising partners for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Processors and Affiliates. We share Commercial Data • Service Providers, such as External Marketing and Advertising Agencies, Data Processors, and Cloud Providers as needed for regular business operations. |
Retention Period | Varies. The data is accessible until the consumer requests to delete their account or according to our internal data retention schedule, which you can find here. |
Category: Internet/Electronic Activity | |
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Examples and Purpose for Collection | Internet/Electronic Activity may contain the following: browsing history, search history, and information regarding your interaction with an Internet website or application. Regular business operations, legal requirements, performance of services, marketing and internal analytics • Service Providers, such as marketing and advertising agencies, data processors, and cloud service providers for regular business operations |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We may share this information with advertising partners for targeted advertising purposes |
Sale | We do not sell this information to third parties. |
Other Disclosures | We may share this information with Processors. We share Internet/Electronic Activity • Service Providers, such as External Marketing and Advertising Agencies, Data Processors, and Cloud Providers, as needed for regular business operations • Cookie Operators to collect information about interactions with the Service or emails, including information about your browsing and activity behavior. |
Retention Period | Varies. The data is accessible until the consumer requests to delete their account or according to our internal data retention schedule, which you can find here. |
Category: Sensory Data | |
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Examples and Purpose for Collection | Sensory Data may contain the following: audio recordings of customer care calls, research interviews, client testimonials, and profile pictures. Regular business operations, legal requirements, performance of services, marketing and internal analytics |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We do not engage in targeted advertising or share this information for targeted advertising purposes. |
Sale | We do not sell this information to third parties |
Other Disclosures | We do not otherwise share this information to third parties |
Retention Period | Varies. The data is accessible until the consumer requests to delete their account or according to our internal data retention schedule, which you can find here. |
Category: Professional Data | |
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Examples and Purpose for Collection | Professional Data may contain the following: professional memberships, schools attended, or employment-related information. Regular business operations, legal requirements, performance of services, marketing and internal analytics |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We may share this information with advertising partners for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Processors, Affiliates, Other Users of our services, and Advertising Partners. We share Professional Data • Service Providers, such as marketing and advertising agencies, data processors, and cloud service providers for regular business operations. |
Retention Period | Varies. The data is accessible until the consumer requests to delete their account or according to our internal data retention schedule, which you can find here. |
Category: Inferences | |
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Examples and Purpose for Collection | Inferences may contain the following: creating a profile about a user reflecting the user’s preferences, characteristics, attitudes, or abilities. Regular business operations, legal requirements, performance of services, marketing and internal analytics |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We may share this information with advertising partners for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Affiliates and Business Partners. We share Inferences • Service Providers, such as External Marketing and Advertising Agencies, Data Processors, and Cloud Providers as needed for regular business operations. • Third-Party Business partners to enable colleges, universities, and other providers of Education-related Products and Services to learn about and connect directly with students. |
Retention Period | Varies. The data is accessible until the consumer requests to delete their account or according to our internal data retention schedule, which you can find here. |
Category: Imprecise Geolocational Data | |
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Examples and Purpose for Collection | Imprecise Geolocational Data may contain the following: GPS, WiFi, cellular data, and radio frequency ID (RFID). We collect Imprecise Geolocational Data in order to share it with third parties to run marketing and advertising campaigns. |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We may share this information with advertising partners for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Processors and Advertising Partners. We share Imprecise Geolocational Data to enable our processors to conduct marketing campaigns on our behalf. |
Retention Period | We do not retain this data. |
Category: Educational Data | |
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Examples and Purpose for Collection | Educational Data may contain the following: School attended or attending, ACT score. Regular business operations, legal requirements, performance of services, marketing and internal analytics • Third parties or affiliates to enable colleges, universities, and other providers of education-related products and services to learn about and connect directly with students. |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We do not engage in targeted advertising or share this information for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Processors, Affiliates, Other Users of our services, and Business Partners. We share Educational Data • Service Providers, such as marketing and advertising agencies, data processors, and cloud service providers for regular business operations. |
Retention Period | Varies. The data is accessible until the consumer requests to delete their account or according to our internal data retention schedule, which you can find here. |
The table below outlines the categories of Sensitive Personal Data Encoura collects about US residents, what we use that data for, and whether and how it is shared with third parties. Encoura obtains affirmative consent from US residents to process Sensitive Personal Data to the extent required by US Privacy Law. US residents who....third-party have given Encoura consent to process their Sensitive Personal Data may withdraw that consent by visiting the Consumer Rights Request page or calling our toll-free number at 1-800-862-7759.
We collect Sensitive Personal Data:
Category: Sensitive Category Data | |
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Examples and Purpose for Collection | Sensitive Category Data may contain the following: Race and ethnicity. Providing to our 3rd party scholarship search company to provide students with additional scholarship opportunities that consider race and ethnicity. As well as sharing with educational providers and services to provide students and educators with educational and academic opportunities that may meet their needs. |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We do not engage in targeted advertising or share this information for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Processors, Affiliates, and Other Users of our services. We share Sensitive Category Data to provide educational products and services as part of our regular business operations, legal requirements, and internal analytics for product improvement. |
Retention Period | Varies. We retain this data until the user requests to delete their account or according to our internal data retention schedule, which you can find here. |
Category: Children's Data | |
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Examples and Purpose for Collection | Children's Data may contain the following: Age, gender, Race and ethnicity, school, GPA, zip code. to provide educational products and services as part of our regular business operations, legal requirements, and internal analytics for product improvement. |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We may share this information with advertising partners for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Affiliates, Other Users of our services, Business Partners, and Advertising Partners. We share Children's Data To provide educational products and services as part of our regular business operations, to enable our processors to provide customer service on our behalf, legal requirements, and internal analytics for product improvement. |
Retention Period | Varies. We retain this data until the user requests to delete their account or according to our internal data retention schedule, which you can find here. |
Category: Financial Data | |
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Examples and Purpose for Collection | Financial Data may contain the following: payment and billing information. Fulfilling a member's order. |
Profiling | We do not use this information for profiling in furtherance of decisions that produce legal (or similarly significant) effects. |
Targeted Advertising | We do not engage in targeted advertising or share this information for targeted advertising purposes |
Sale | We do not sell this information to third parties |
Other Disclosures | We may share this information with Processors. We share Financial Data to enable our processors to provide customer service on our behalf. |
Retention Period | Varies. Financial data is retained by our third-party service providers and stored according to their retention policies. |
In addition to the purposes listed above, we may use the information we collect:
We share Personal Data with the following categories of third parties:
Processors. We may share any information we collect with processors retained in connection with the provision of our Services. These companies are only permitted to use this information on our behalf and according to our instructions. Our processors are not permitted to use your information for their own purposes.
Our Affiliates. We may share your information with our affiliates, subsidiaries, and representatives as needed to provide our Services.
Other Users. Content you post on our systems, such as comments or reviews, may be displayed to other Users as appropriate.
Our Business Partners. We may share relevant information about you with our business partners to provide you with exclusive offers for products and services that may interest you.
Our Advertising and Analytics Partners. We use analytics services to collect and process certain analytics data, as detailed below. We also work with third-party services to conduct advertising via cookies. These third parties may also collect information about your use of other websites, apps, and online resources. These partners include:
Please note that this list may be updated from time to time to provide you with the latest information. For more information about your choices regarding how these partners use your information, see the Your Choices section below.
We may also share your Personal Data with other parties for the following reasons:
As Required by Law. We may share your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. In particular, we may share relevant information with the appropriate third parties if you post any illegal, threatening, or objectionable content on or through our Services.
Events. We may share your information with event partners or co-sponsors to facilitate the events for which you register.
Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or in which we sell, liquidate, or transfer all or a portion of our assets. The same general provisions of this Privacy Notice will govern the use of your information following any of these events.
Consent. We may also share your information with your permission.
For more information on how we share the information we collect, see the Categories of Non-Sensitive and Sensitive Personal Data tables above. We do not sell Personal Data to anyone.
From time to time, you may receive marketing or other informational email messages from us. You can unsubscribe from our promotional and informational emails via the link provided in the emails. Users may continue to receive administrative messages necessary to service User accounts after opting out of receiving promotional messages from us.
Most web browsers allow you to manage cookies through the browser settings. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org.
You can learn more about Google’s privacy practices and your options about how they use your information on Google’s website. You can also install the Google Analytics Opt-out Browser Add-on. Meta, the parent company of Facebook, provides information about how it uses the information it collects through our Services in its Data Policy. You can also learn specifically about Facebook’s advertising practices on its website. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. You can visit those organizations’ websites to learn about how you may opt out of receiving web-based personalized ads from their member companies. You can also access any settings offered by your mobile operating system to limit ad tracking. To inquire about your choices regarding our business partners generally, contact us at privacy@encoura.org.
US residents have the following rights under US Privacy Law:
If you are a US resident, you can submit a request to exercise your personal data rights and use our Consumer Rights Request page or calling our toll-free number at 1-800-862-7759. Encoura also processes opt-out requests sent by Universal Opt-Out Mechanisms (also referred to as “Opt-Out Preference Signals”) frictionlessly in compliance with US Privacy Law. You can send an Opt-Out Preference Signal for our business to process frictionlessly by visiting our website using a device or browser that broadcasts commonly used and recognized Opt-Out Preference Signals. We will apply the Opt-Out Preference Signals we receive We will apply the Opt-Out Preference Signals we receive to the browser or device that sent the signal using One Trust Geolocation rules and cookies preferences. Please be aware that we do not accept or process rights requests submitted through other means.
To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will verify your identity by You will need to provide us with certain information such as your name, email address, physical address, or other information, as relevant, so we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information requested. If you do not complete the verification process, we may be unable to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose.
We will respond to your rights request within 45 days (or within 15 days when required by US Privacy Law), and in certain cases we may inform you that we will need an additional 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay acting on your request until we can appropriately verify your identity and the request as authentic. Also note that each of your rights are subject to certain exceptions that may permit or require us not to process your request.
We reserve the right to decline to process, or charge a reasonable fee for, requests from a US resident that are manifestly unfounded, excessive, or repetitive.
You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by using the method(s) described above. We may require verification of your authorized agent’s authority in addition to the information we require for verification of your identity. If an authorized representative is requesting information about someone else's data, use our Authorized Agent Request page.
US Privacy Law gives US residents the right to direct a business that “sells” their Personal Data or shares it for targeted advertising purposes to stop selling and/or sharing their Personal Data at any time. As used here, “selling” means exchanging Personal Data with a third party for money or anything of value, and targeted advertising is the practice of displaying advertisements to a person that are selected based on that person’s activities over time and across non-affiliated websites or applications. In certain situations, and as detailed more fully above, we share for targeted advertising Personal Data with third parties. You can opt out of the sharing of your Personal Data for targeted advertising purposes by visiting the Consumer Rights Request Page or calling our toll-free number at 1-800-862-7759.
You have the right to limit some uses of Sensitive Personal Data. In general, you may direct companies not to use your Sensitive Personal Data except as necessary to provide goods or services you have requested or to further certain other exempt purposes.
However, we only use Sensitive Personal Data for purposes that are exempt from this right, such as to provide you with goods or services you have requested, to detect and prevent security incidents, or verifying the quality of our goods and services. The full list of these exempt purposes is specified in the California Code of Regulations, Title 11, Section 7027(m).
We sometimes share for targeted advertising the Personal Data of US residents under 16 years of age, as permitted by US Privacy Law.
Further, in compliance with US Privacy Law, we share for targeted advertising Personal Data of US residents under 18 years of age only when they have affirmatively opted in. US residents under the age of 18 may submit opt-in requests by Opt-in for ages 13 and up occurs in the app, the paper survey, and the website user portal. The user setup in which they opt into the collection and sharing of information and then a second screen to confirm and verify opt-in. Individuals under the age of 13 are excluded from the use of the app and website. If they do not agree, their information will not be shared with affiliates. They can change their response at any time to opt in or out without submitting a rights request.
We comply with the Children’s Online Privacy Protection Act (“COPPA”), in addition to US Privacy Law, with respect to any Personal Data we collect or use from children under the age of 13.
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the content provided by, or the privacy practices of, these third parties. Please be aware that this Privacy Notice does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
We make reasonable efforts to protect your information by using administrative, technological, and physical safeguards designed to improve the security of the information we maintain and protect it from accidental loss, unauthorized access or use, or any other inappropriate or unlawful processing. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your information.
Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By using our Services, you consent to the transfer, storage, and processing of your information as described in this Privacy Notice.
We will post any adjustments to the Privacy Notice on this page, and the revised version will be effective when it is posted. If we make material changes, we may notify you by sending an email to the address we have on file. We encourage you to read this Privacy Notice periodically to stay up to date about our privacy practices.
If you have any questions, comments, or concerns about our processing activities, please email us at privacy@encoura.org.
Last updated: August 28, 2024