Privacy Policy

Effective: January 1, 2020

This Privacy Policy (the“Privacy Policy”) governs the manner in which Ivy Guru LLC (“Ivy Guru”), a limited liability company organized under the laws of the State of Missouri, collects, uses, maintains, and discloses information collected from users (each, a“User”) of its www.ivyguru.com website, applications, and technology platform and any derivative or affiliated Sites on which this Privacy Policy is posted (collectively, the“Site”). The Site is owned and operated by Ivy Guru. Ivy Guru offers courses, classes, self-study materials, and tutoring for college and graduate school admissions tests by a wide range of Instructors (“Instructor(s)”) featured on the Site (the“Test Prep Service”). The Site also features an extensive gallery of Admissions Consultants (“Admissions Consultant(s)”) for students who are seeking to connect with the right undergraduate and graduate Admissions Consultant based upon the particular needs of each student and provides a means for the independent Admissions Consultants to advertise and provide their consulting services to potential customers through the Site (the“Admissions Consultant Matching Service” and together with the Test Prep Service, the“Service”). Please note that this Privacy Policy covers Ivy Guru’s practices regarding information collected from its Site.

The Information Ivy Guru Collects and Receives

Like most website owners or operators, Ivy Guru collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose in collecting non-personally identifying information is to better understand how our visitors use our Site.

Certain visitors to Ivy Guru’s Site choose to interact with us in ways that require us to gather personally-identifying information. The amount and type of information that we gather depends on the nature of the interaction.

Contact Information. Ivy Guru stores submitted contact data (such as a customer’s name, mailing and e-mail addresses, and phone number). If you communicate with Ivy Guru by e-mail, make telephone or cell phone calls, communicate through electronic devices or other interactive devices, complete online forms, surveys or contest entries, or communicate with Ivy Guru by any means, the information provided in such communication may be collected by Ivy Guru.

Transactional Data. Those who engage in transactions with us online are asked to provide additional information, such as the personal and financial information required to process those transactions. We use a token system to communicate with our third-party vendors.

Unique Identifiers. Ivy Guru also collects potentially personally-identifying information like Internet Protocol (IP) addresses. We do not use such information to identify our visitors, however, and do not disclose such information, other than under the same circumstances that we use and disclose personally-identifying information, as described below. A User browsing the Site without registering an account or affirmatively providing personally identifiable information to Ivy Guru does so anonymously.

Preference and Demographic Information. Ivy Guru may collect information regarding your preferences, such as target graduate and undergraduate schools and goal test scores. We may also collect contact data demographic data (such as a customer’s zip code, age, gender, and interests).

Automatically Collected Information. Ivy Guru may also collect information about how customers use our Site, for example, by tracking the number of unique views received by the pages of the Site, or the domains from which customers originate. When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and the device identifier.

Analytics. We use certain third-party services to assist us in analysis, auditing, research, and reporting regarding Ivy Guru services. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, we use Google Analytics to help collect and analyze certain information for the purposes discussed in this Policy. You may opt out of the use of cookies by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Information Sharing

It is Ivy Guru’s policy to respect your privacy regarding any information we may collect from a variety of sources, including: through the Site; email, phone, or any other communications we have with you; and information we collect about you from third party sources. We treat the confidential information you share with us, such as academic performance and any financial information, with the utmost respect. Ivy Guru will not disclose student records with third parties under any circumstance, except as specifically set forth in this Privacy Policy, or as required by applicable law. Ivy Guru uses and discloses your personal information only as follows:

(A) It’s Your Data. Ivy Guru will never sell your information to anyone for marketing purposes; however, if you would like to make an opt-out request related to that, you can make the request to customersupport@ivyguru.com. Ivy Guru will also never share your information with non-affiliated companies, except as set forth in this Privacy Policy, in Ivy Guru’s Terms of Use, in the Terms of Customer Account Use, in the Independent Contractor Agreement, or in any other agreement between you and Ivy Guru, or as required by applicable law. We may share a student’s information with the Instructor(s) or Admissions Consultant(s) who may or will be providing instruction or consulting, respectively, to the student so that they may evaluate the engagement and personalize or tailor to the student’s needs, where applicable. In each case, we collect such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with Ivy Guru. Ivy Guru may also share information with third party businesses who process payments on our behalf, who help us develop our business, who inform our marketing strategy, who provide cloud storage services, who provide professional services, and who provide communication software.

(B) Analytics and improvements. To analyze usage and improve the Service based on user actions, market research, project planning, troubleshooting problems, and detecting and protecting against error;

(C) Third-party contractors. Ivy Guru uses third party services to give you the best possible payment processing experience. These contractors are either bound by these same privacy restrictions, or have privacy policies/restrictions of their own that apply;

(D) Terms of Use enforcement. In order to enforce Ivy Guru’s Terms of Use;

(E) Partner sites. In the event that you access the Service as brought to you by one of our co-brand partners, through a co-branded URL, your email address used for registration on the Service may be provided to that co-brand partner, along with purchase details including confirmation code and booking amount.

(F) Affiliate Sharing. We may share your information with Ivy Guru LLC affiliates or related entities (including but not limited to Varsity Tutors LLC and EduNation, Ltd. (t/a First Tutors)). This Privacy Policy does not cover the practices of Varsity Tutors LLC, First Tutors, or any other affiliate or related entity, each of which has its own policies and practices.

(G) Legal Requirement. We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

(H) Business Arrangements. If Ivy Guru LLC is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain Site-related activities.

User Access and Choice

(A) Update Information. If the personal information on file for you changes, or if you no longer desire our service, you may correct or update it by making the change on our account settings page or by emailing Customer Support at customersupport@ivyguru.com.

(B) Request Data. You can request a report of your user data and Ivy Guru will respond in a timely fashion. You may also request deletion of your personal data and we will follow up with a confirmation upon removal. Reach out to us by completing the form  here.

(C) Information Retention. We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

(D) Newsletter and/or marketing information. If you subscribe to our newsletter(s), we will use your personal information to send you an individualized newsletter. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at the information below.

Cookies/Tracking Technologies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Ivy Guru cookies are necessary to provide you with appropriate content and continued Site visits from day to day. Without the use of cookies, many Ivy Guru services are likely unable to function properly.

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s“help” directory.

If you reject cookies, many areas of the Ivy Guru site may not work as intended, as our test preparation study platforms adapt to your completed activities as you progress during your studies. Ivy Guru uses cookies to remember which activities you have completed and which practice problems you have seen, allowing the site to adapt to your learning progress.

Cookie usage:

(A) In Product Usage. To gather aggregate data on item difficulty, lesson effectiveness, score improvement, and other student performance trends, and to adapt to the progress you have made within the learning applications.

(B) Third Party Cookies. The use of cookies by our partners, affiliates, tracking utility company, or service providers is not covered by our privacy statement. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, or service providers use session ID cookies to make it easier for you to navigate our site.

LSOs

Third Parties, with whom we partner to provide certain features on our Site or to display advertising based upon your Web browsing activity, use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

Behavioral Targeting

We partner with third-party advertising programs to advertise on other sites. These programs use cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. You can manage your preferences for these advertising programs through the following links: Facebook, Google. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Correcting, Updating, Accessing, or Removing Personal Information

To the extent applicable, if a User’s personally identifiable information changes (such as a User’s zip code), or if a User no longer desires to receive non-account specific information from Ivy Guru, Ivy Guru will endeavor to provide a way to correct, update, delete, and/or remove that User’s previously-provided personal data. This can be done by completing a request form here. Additionally, you may request access to the personally identifiable information as collected by Ivy Guru by sending a request to Ivy Guru as set forth above. We will respond to your request within a reasonable timeframe, or otherwise in accordance with applicable law. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For state-specific information or related rights, please see the state-specific sections below.

Legal Disclaimer

Ivy Guru may disclose personally identifiable information at the request of law enforcement or governmental agencies or in response to subpoenas, court orders, or other legal process, to establish, protect, or exercise Ivy Guru’ legal or other rights or to defend against a legal claim or as otherwise required or allowed by law. Ivy Guru may disclose personally identifiable information in order to protect the rights, property, or safety of a User or any other person. Ivy Guru may disclose personally identifiable information to investigate or prevent a violation by User of any contractual or other relationship with Ivy Guru or the perpetration of any illegal or harmful activity.

Security of Information

Ivy Guru discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors, and affiliated organizations that (i) need to know that information in order to process transactions on our behalf or to provide services, and (ii) that have agreed not to disclose it to others. We take all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.

Information about each User that is maintained on Ivy Guru’s systems is protected using industry standard security measures. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at customersupport@ivyguru.com. However, no security measures are perfect or impenetrable, and Ivy Guru cannot guarantee that the information submitted to, maintained on, or transmitted from its systems will be completely secure. Ivy Guru is not responsible for the circumvention of any privacy settings or security measures relating to the Site by any User or third parties.

Links to 3rd Party Sites

Please note that the Site may contain links to other Sites. These linked sites may not be operated or controlled by Ivy Guru. Ivy Guru is not responsible for the privacy practices of these or any other Sites, and you access these Sites entirely at your own risk. Ivy Guru recommends that you review the privacy practices of any other Sites that you choose to visit.

Ivy Guru is based, and this Site is hosted, in the United States of America. If User is from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law and User is visiting, accessing, or otherwise using the Site, please note that any personally identifiable information that User provides to Ivy Guru will be transferred to the United States. Any such personally identifiable information provided will be processed and stored in the United States by Ivy Guru or a service provider acting on its behalf. By providing personally identifiable information to Ivy Guru, User hereby specifically and expressly consents to such transfer and processing and the uses and disclosures set forth herein.

Children’s Privacy

Ivy Guru products are specifically designed to function without third party access to a child’s personal information. Our Site does not collect or retain any personal information from children except as needed to facilitate the Services for that student, who may be a minor. Ivy Guru is committed to complying fully with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). This Site assures the privacy of collected information in accordance with the Ivy Guru’ Privacy Policy.

Ivy Guru is committed to safeguarding the information each User entrusts to Ivy Guru and believes that every User should know how it utilizes the information collected from each User. Other than free information and materials that do not require any registrations or identifying information, the Site is not directed at children under 13 years of age, and Ivy Guru does not knowingly collect personally identifiable information from children under 13 years of age online. For purposes of using the Site as a platform to connect with Instructors and Admissions Consultants, Parents may supply information such as name or age of their children in order for Ivy Guru to assist facilitate the connection between student and Instructor or Admissions Consultant. Ivy Guru may store this information in a secure digital format. Parents or guardians of children under 13 years of age may review or have deleted any personal information previously provided by the child, parent, or guardian that is ultimately collected by Ivy Guru, if any, to connect the child with an Instructor or Admissions Consultant. If you seek to review or delete such information, contact Ivy Guru at the below phone number or email address indicating what you would like to have done and Ivy Guru will contact you for purposes of taking the requested action, including but not limited to refusing to permit the information’s further collection or use.

Your California Privacy Rights

Subject to certain limitations, the California Consumer Privacy Act (CCPA) provides California consumers the right to request more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may occur, and to not be discriminated against for exercising such rights. California consumers may make a request pursuant to their rights under the CCPA by completing the request form here. We will verify your request using information associated with your account, including email address, and may need to request additional information.

Your Nevada Privacy Rights

Nevada Revised Statute Section 603A permits a User that resides in Nevada the right to submit a verified request that Ivy Guru not sell such User’s covered information. Ivy Guru does not sell any covered information as defined under Nevada Revised Statute Section 603A. Nevada consumers may make a request pursuant to such rights by completing the request form here. We will verify your request using information associated with your account, including email address, and may need to request additional information.

Changes to this Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, then we may notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting Ivy Guru

If you have any questions or comments about this Privacy Policy, you may contact Ivy Guru via the following methods:

Ivy Guru LLC

125 West 25th Street,

New York, NY 10001

customersupport@ivyguru.com