We Respect the privacy of every individual who visits this site.

This Privacy Policy (the “Privacy Policy”) explains the manner in which Best in Class Education, Inc. (“Best in Class,” “we,” “our,” or “us”) collects, uses, maintains, and discloses personal information collected from users (each, a “User”) of its www.bestinclasseducation.com website, applications, technology platform, and any derivative or affiliated websites owned and operated by Best in Class (collectively, the “Site” or “Website”).
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. In some cases, we may provide you with additional notice (such as a statement on our website). Please review this Privacy Policy from time to time so you understand our privacy practices and your choices regarding how we use personally identifiable information we collect from you from our Site (“Personal Information”).

We respect and understand the importance of privacy and security for all users of our Site. Any information collected by us is used primarily by Best in Class – and its affiliate companies – to improve our business strategy, operations and contact our users for marketing and operational purposes. Persons who supply us with their telephone numbers or email addresses on-line may receive telephone or email contact from us with information regarding special promotions, new products, services and/or upcoming events.

You may choose to submit your Personal Information (including but not limited to your name, address, email address and telephone number) to us at several different points on the Website. From time to time, we may request Personal Information from you in order to deliver requested materials to you, respond to your questions, or deliver a product or service. We will not share this information in ways different from what is disclosed in this statement

For Parents of Children Under The Age of 13

For any user under the age of 13, whose Personal Information we collect, we must have permission from such user’s parent or legal guardian before we collect or use any Personal Information of such user on the Site. You are welcome to contact us at (888) 683-8108 or
privacy@bestinclasseducation.com to review any Personal Information we have collected about your child. You may request that we delete this information or specify that we collect no more of your child’s information. We will need to verify the identity of anyone requesting information about a child under the age of 13 to ensure that the person is in fact the child’s parent or legal guardian.

Collecting and Using Personal Information

When you visit, navigate or communicate with us through our Site, we will not collect Personal Information about you unless you provide us that information voluntarily. Any nonpublic Personal Information that you may provide via the Website will be used solely for the purpose stated on the page where it is collected. In some cases, and in all cases where required by law or regulation, you will be able to update the information that you provide to us either by sending us an email or, where you have established personal profiles with us, by updating your profile online. Please refer to the specific pages where data is collected for more information. We will not sell, license, transmit or disclose this information outside of Best in Class and its affiliated companies unless: (a) expressly authorized by you; (b) necessary to enable Best in Class contractors or agents to perform certain functions for us; or (c) required or permitted by law. In all cases, we will disclose the information consistent with applicable laws and regulations and we will require the recipient to protect the information and use it only for the purpose it was provided.

Information We Collect

We collect information through the sources described below.

Information We Collect

We collect Personal Information and non-personal information from you (such as your or your parents’ or guardians’ name, address, email address, phone number, credit card number, school name, grade level, year of graduation, date of birth, GPA, test scores, academic interests, transcripts, photos, employer name and job title, library card number, race, and military or veteran status) when you:

• register or create an account on our Site;
• call us;
• purchase our products or services;
• provide us or upload to our Site messages, documents, and other files and content in the course of your use of our products or services;
• enter sweepstakes or other promotions;
• respond to surveys or questionnaires or submit testimonials;
• provide us information at events we host, sponsor, or participate in;
• provide us information on our Site or submit online forms so that we can contact you about products or services you may be interested in or answer questions you have; or
• when you provide us information by other means.

Information from Third Parties.

We may collect Personal Information and non-personal information about you (such as your name, email address, student ID number, grade level, and courses you are taking) from third parties with whom we have a business relationship (such as our organizational customers, resellers, licensees, and franchisees).

We may obtain personal and non-personal information from publicly and commercially available sources, including organizers of events you may attend.

Information Collected Automatically.

We collect information (such as your IP address, your browser type, the content of any undeleted cookies that your browser previously accepted from us, the referring website address, and operating system) from your browser when you visit our Site.

We, our service providers and other vendors, and our affiliates and third parties which may display advertisements on our Site may use tracking technologies such as cookies (see Other Information and Cookies section below) and pixel tags to collect information about your online interactions with our Site and our emails.

We collect information when you purchase our products and services and use our products and services (such as recording online sessions, producing transcripts of online tutoring sessions, and tracking the drills and practice tests that you take online).

We automatically record calls to our call center.

How We Use Information

We may use your Personal Information to:

• provide you with and personalize our products and services;
• create and manage your account, process your orders, and provide you customer service;
• maintain our internal records and otherwise manage our business;
• send you newsletters and advertisements and otherwise correspond with you about products, services, events, and other organizations that we think may interest you;
• ask for your reviews and testimonials and send you surveys and questionnaires;
• improve our products, services, and Site;
• administer sweepstakes and other promotions;
• develop and display content and advertising tailored to your interests on our Site and other sites, provide our advertisements to you when you visit other sites, and analyze the effectiveness of our advertisements;
• perform research and analysis about your use of or interest in our products and services, the products or services offered by others, and our Site, and develop new products and services;
• detect, prevent, or investigate illegal activity or misuse of our products or services and enforce our legal rights; and
• perform functions as otherwise described to you at the time of collection.

We may use non-personal information for any lawful purpose.

Third Parties to Whom We Disclose Information

We share your Personal Information with third parties as described below. We do not disclose your Personal Information information to third-parties for their direct marketing purposes except as may be described below.

Organizations and Persons who Arrange for Your Participation in Our Programs

We work with certain organizations to provide programs such as tutoring, test preparation, and college admission counseling. Your organization may arrange for your participation in these programs and negotiate a special price or trial offer, or purchase (or subsidize) products or services on your behalf. We may share your personal and non-personal information that we collect through your participation in these programs (such as test scores, transcripts or recordings of online tutoring and online class sessions, comments you leave in post-session surveys, and details regarding your usage of our programs) with the organization arranging for your access to these programs or with your parents or guardians. In addition, your school may require us to share such information with others legally entitled to access your academic records, such as your state department of education. If you use a promotion code at our Site to create an account or add products or services, we may let the source of that promotion code know that you used that code.

Service Providers and Other Vendors

We may share your Personal Information with our service providers and other vendors, such as those who help deliver our products and services, process transactions (such as charging your credit card when you make purchases), market our products and services, obtain reviews and testimonials, and otherwise help us operate our business.

Affiliates

We may share your Personal Information with our affiliates.

Legally Compelled Disclosures and Safety

We may disclose Personal Information when compelled to do so by government authorities or otherwise as required or permitted by law, such as to respond to court orders and subpoenas. We may also disclose Personal Information to protect the safety of others and when we have reason to believe that someone is causing injury to or interfering with our rights or property or the rights or property of others.

Business Transfer

If we or all or a portion of our business is acquired by one or more third parties as the result of an acquisition, merger, sale, reorganization, consolidation or liquidation, Personal Information may be included in the transferred assets.

Authorized Disclosure

We may share your Personal Information with third parties when you authorize the disclosure.

Non-Personal Information

We may share non-personal Information with any third party for any lawful purpose.

Your Access to Information

You may review and correct the information that is accessible to you by calling (888) 683-8108.

Your Information and Opting Out

If you do not wish to receive periodic mailings or emails, or telephone contact concerning our Website, our services, reminders and/or upcoming events, you may opt-out of receiving such marketing or promotional communications by sending us a written request to the address listed below or by following the opt-out instructions in the email you receive from us. However, if you choose to opt-out of marketing or promotional communications, we reserve the right to contact you regarding your orders, technical support and any other matter that might affect our service to you, and/or your use of the Website, as applicable.

Your Email

We welcome your comments or questions about the Website and have provided email boxes for that purpose. We will share your comments and questions with our customer service representatives and those employees most capable of addressing your questions and concerns. Please note your email, like most, if not all, non-encrypted Internet email communications, may be accessed and viewed by other Internet users, without your knowledge and permission, while
in transit to us. For that reason, to protect your privacy, please do not use email to communicate information to us that you consider confidential. If you wish, you may contact us instead by telephone at the numbers provided at various locations on the Website.

Other Information and “Cookies”

You should also be aware that when you visit the Website, we collect certain information that does not identify you personally, but provides us with “usage data,” such as the number of visitors we receive or what pages are visited most often. This data helps us to analyze and improve the usefulness of the information we provide on the Website. Like most commercial website owners, we may use what is known as “cookie” technology. A “cookie” is an element of data that a website can send to your browser when you link to that website. It is not a computer program and has no ability to read data residing on your computer or instruct it to perform any step or function. By assigning a unique data element to each visitor, the website is able to recognize repeat users, track usage patterns and better serve you when you return to that site. The cookie does not extract other Personal Information about you, such as your name or address.

Linking To Other Sites

From time to time, the Website may provide links to other websites, not owned or controlled by Best in Class, that we think might be useful or of interest to you. We cannot, however, be responsible for the privacy practices used by other website owners or the content or accuracy of those other websites. This Privacy Policy does not address the information practices of these other websites, and we encourage you to carefully read the posted privacy policies of such sites. Links to various non-Best in Class websites do not constitute or imply endorsement by Best in Class of these websites, any products or services described on these sites, or of any other material contained in them.

Using Caution When Sharing Information with Others

When you contribute to a public area or feature of our Site, such as a chat room, bulletin board, list serve, blog, or wiki, the information that you submit will be made available to the general public and may be captured or stored by other users of the Site. Therefore, we recommend that you do not submit any sensitive information to such areas of our Site, including your full name, home address, phone number, financial information or any other information that you would not want to be made public or would enable other users to locate you or contact you.

Security

Beset has adopted and adheres to stringent security standards designed to protect non-public Personal Information on the Website against accidental or unauthorized access or disclosure. We aim to take reasonable steps to help protect your Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure and therefore we are unable to guarantee the security of your Personal Information. If you have reason to believe that your interaction with us is no longer secure, please let us know (see “Contact Us: Questions or Concerns” below).

Nevada Privacy Rights

We do not sell the Personal Information of Nevada consumers without their authorization, but Nevada consumers may submit an email to privacy@bestinclasseducation.com to request that we do not sell their Personal Information in the future.

California Consumer Privacy Act Rights

The information in this California Consumer Privacy Act Rights section applies only to California consumers. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this California Consumer Privacy Act Rights section.

Personal Information We Collect

We may collect, and in the past 12 months have collected, the following categories of personal information:

• Identifiers (such as name, address, email, cookies, IP address, date of birth, student ID number, and library card number)
• Categories of personal information listed in the California Customer Records statute (such as phone number, credit card number, and education)
• Characteristics of protected classifications under California or federal law (such as military or veteran status and race)
• Commercial information (such as purchase history)
• Internet or other electronic network activity information (such as interaction with our Sites)
• Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)) (such as test scores, GPA, course enrollments, and transcripts)
• Audio, electronic, visual, thermal, olfactory, or similar information (such as recorded voice, recorded video, and photos)
• Professional or employment-related information (such as employer information and job title)
• Inferences drawn from other categories of personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes (such as likelihood of making a purchase based on internet or other electronic network activity)

Sources from which Personal Information is Collected

We collect personal information from the categories of sources listed below, as described in more detail in the “Information We Collect” section above:

• Consumers
• Third parties with whom we have a business relationship (such as our organizational customers, resellers, licensees, and franchisees)
• Other users who refer you to us
• Schools, colleges and universities who provide information for the purpose of conducting surveys
• Publicly and commercially available sources, including organizers of events you may attend
• Browsers and tracking technologies
• Our service providers and other vendors

Purposes for which Personal Information Will Be Used

We may use personal information for the following purposes:

• provide you with and personalize Best in Class products and services;
• create and manage your account, process your orders, and provide you customer service;
• maintain our internal records and otherwise manage our business;
• send you newsletters and advertisements and otherwise correspond with you about products, services, events, and other organizations that we think may interest you;
• ask for your reviews and testimonials and send you surveys and questionnaires;
• improve our products, services, and Site;
• administer sweepstakes and other promotions;
• develop and display content and advertising tailored to your interests on our Site and other sites, provide our advertisements to you when you visit other sites, and analyze the effectiveness of our advertisements;
• perform research and analysis about your use of or interest in our products and services,
• the products or services offered by others, and our Site, and develop new products and services;
• detect, prevent, or investigate illegal activity or misuse of our products or services and enforce our legal rights; and
• perform functions as otherwise described to you at the time of collection.

Personal Information Sold or Disclosed for a Business Purpose

We do not sell personal information of California consumers, have not sold personal information of California consumers in the preceding 12 months, and do not have actual knowledge that we sell the personal information of minors under 16 years of age.

We may disclose personal information to a third party for a business purpose. In the preceding 12 months, we have disclosed the categories of personal information listed below to organizations and persons who arranged for consumers’ participation in our products and services and our service providers and other vendors:

• Identifiers
• Categories of personal information listed in the California Customer Records statute
• Characteristics of protected classifications under California or federal law
• Commercial information
• Internet or other electronic network activity information
• Non-public education information
• Audio, electronic, visual, thermal, olfactory, or similar information
• Professional or employment-related information
• Inferences drawn from other categories of personal information

Your Right to Know

You have the right to request that we disclose information to you about our collection, use, disclosure, and sale of your personal information in the 12-month period preceding your request. Once we receive and confirm your verifiable consumer request, then subject to exceptions provided under the CCPA and based on your request, we will disclose to you:

• The categories of personal information we collected about you
• The categories of sources from which we collected your personal information.
• The business or commercial purpose for collecting or selling your personal information.
• The categories of third parties with whom we shared your personal information.
• The specific pieces of personal information we collected about you
• If we sold your personal information, the categories of personal information that was sold to each category of recipient.
• If we disclosed your personal information for a business purpose, the categories of personal information that was disclosed to each category of recipient.

Your Right to Deletion

You have the right to request that we delete your personal information that we have collected, subject to exceptions provided under the CCPA. Once we receive and confirm your verifiable consumer request, then unless an exception applies, we will delete your personal information from our records and direct our service providers and other vendors to delete your personal information from their records.

Your Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of the privacy
rights conferred by the CCPA.

Submitting Requests

To exercise your right to know or right to deletion described above, please submit a verifiable
consumer request to us by:

• Calling us at (888) 683-8108; or
• Completing a request form located at www.bestinclasseducation.com/ccpa and mailing
  it to the address listed on the form.

You may only make a verifiable consumer request to know twice within a 12-month period.
You may authorize another person to act as your agent to submit requests on your behalf. Unless you provide the agent with power of attorney under the California Probate Code, you will need to provide the agent a written and signed authorization. You may also submit requests on behalf of your minor child.

Verification

We have the legal obligation to and will verify your identity before fulfilling your request. We will ask you to provide us data points that we have about you to verify your identity.
If you authorize another person to act as your agent to submit requests on your behalf, then unless you provide the agent with power of attorney under the California Probate Code, we will ask the agent to provide us the written and signed authorization that you provided to the agent, we will confirm with you that you did provide the authorization, and we will verify your identity. If you submit a request on behalf of a minor child, we will ask you to provide us information about your child that allows us to determine that you are the parent or guardian of the child. If the child is under the age of 13, we will ask you to sign a form declaring under penalty of perjury that you are the parent or guardian of the child.

Our Response to Your Request

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason in writing. We will deliver our written response by mail or electronically. If we are unable to comply with a request,
our response will explain why.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Accessibility of this Privacy Policy

Commercially available screen reader programs should be able to read this Privacy Policy. As a web page, this Privacy Policy may be printed as a document.

Users Outside of the United States

By providing Personal Information to or through this Site, you understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories, in accordance with applicable law. We are a United States and we do not operate in or market to individuals in the European Economic Area (“EEA”), including any EEA citizens located outside of the EEA. Any processing of personal data of individuals in the EEA by us is incidental. We do, however, recognize the rights of individuals in the EEA and, therefore, request that any individuals located in the EEA who have questions about or requests related to the personal data we collect to contact us at privacy@bestinclasseducation.com.

Changes To This Statement

We may change this statement from time to time; when updates are made, the privacy policy version date (located at the bottom of this policy) will also be updated to reflect that a revision occurred. We encourage you to periodically reread this policy to see if there have been any changes that may affect you. This statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Contact Us: Questions or Concerns

If you have any questions regarding this Policy, please contact us at:
Best in Class Education, Inc
2100 East Spruce St.
Seattle, Washington 98122
Phone: (888) 683-8108
Email: privacy@bestinclasseducation.com