Privacy Policy

Level All Privacy Policy

Effective as of August 29, 2023.
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This “Privacy Policy” describes the privacy practices of Level All Inc. and our subsidiaries and affiliates (collectively, “Company”, “we”, “us”, or “our”) in connection with the www.levelall.com website and any other website that we own or control and which posts or links to this Privacy Policy (collectively, the “Websites”), and the rights and choices available to individuals with respect to their information.

THIS PRIVACY POLICY DOES NOT APPLY TO CUSTOMERS WHO HAVE SIGNED A SEPARATE AGREEMENT, including district, high school, university and institutional customers (each, an “Enterprise Customer”) and the students, parents/representatives, teachers, and administrative users they authorize to use these products and services (each, an “Enterprise User”).

Company provides high-quality tech-enabled products and services (including the Websites) that help high school students and their families make the most informed decisions as they navigate high school and post-secondary opportunities. Company provides these products and services in two ways:

1. Enterprises: We provide these products and services to Enterprise Customers and Enterprise Users as defined above.;

2. The Public: We also provide these products and services directly to students, parents/representatives and others who access Company’s products or services on their own, such as those who sign up directly through our Websites (such users, “Public Users” or “Users”).

This Privacy Policy only covers the personal information we collect from our Public Users. If you are an Enterprise User (including an Enterprise User who is a student), please note we act as a service provider and processor for our Enterprise Customers. This means we only use and process Enterprise Users’ personal information on behalf of our Enterprise Customers (who act as controllers of such information), and in accordance with our agreements with our Enterprise Customers, which govern our use and processing of this personal information. If you are an Enterprise User who is a student, this personal information may be subject to the Family Educational Rights and Privacy Act (“FERPA”), meaning we will only use personal information that is considered to be “personally identifiable information” maintained as part of “education records” (as both are defined under FERPA) for legitimate educational interests, which include providing the Websites. Enterprise Customers may have their own privacy policies that govern their Enterprise Users’ personal information that is collected in connection with their use of our products and services — such privacy policies will govern how each Enterprise Customer processes and shares personal information and explain any rights their Enterprise Users may have to such personal information (including any rights under FERPA).

Table of Contents

Personal Information We Collect
How We Use Your Personal Information
How We Share your Personal Information
Your Choices
Other sites, mobile applications and services
Security practices
International data transfers
Children and Students
Changes to this Privacy Policy
How to Contact Us

Personal Information We Collect
‍Information you provide to us. Personal information you provide to us through the Websites or otherwise includes:

Contact information, such as your first and last name, email and mailing addresses, and phone number, and the name and contact information for your parent or legal guardian.
Account information, such as your username and password that you use to create an account with us.
Account profile information, such as your birthdate, photograph, interests (including post-secondary education and career interests), and preferences.
Registration information, such as information that may be related to an event you register for.
Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
Demographic Information, such as your city, state, country of residence, postal code, affiliated school, graduation year, schools applied to, and age.
Transaction information, such as information about payments to and from you and other details of products or services you have purchased from us.
Usage information, such as information about how you use the Websites and interact with us, including information associated with any content you upload to the Websites or otherwise submit to us, and information you provide when you use any interactive features of the Websites.
Marketing information, such as, with respect to non-student Users, your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from other third parties. We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly available sources and data providers. We may also obtain your personal information from people who refer you.
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Cookies and similar technologies.
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Websites, including but not limited to, your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, the website you visited before browsing to our Websites, general location information such as city, state or geographic area; information about your use of and actions on the Websites, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites.

On our webpages, this information is collected using cookies, web beacons, and similar technologies, and our emails may also contain web beacons.

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our Websites.

Web browsers may offer Users of our Websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Websites may not function correctly.
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Referrals
Users of the Websites may have the opportunity to refer friends or other contacts to us. If you are an existing User, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
To operate the Websites. We use your personal information to:

provide, operate and improve the Websites;
provide information about our products and services;
establish and maintain your user profile on the Websites;
communicate with you about the Websites, including by sending you announcements, updates, security alerts, and support and administrative messages;
communicate with you about events or contests in which you participate;
understand your needs and interests, and personalize your experience with the Websites and our communications;
provide support and maintenance for the Websites; and
to respond to your requests, questions and feedback.

For research and development. We analyze use of the Websites to analyze and improve the Websites and to develop new products and services, including by studying User demographics and use of the Websites.
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To send you marketing and promotional communications. We may send you Company-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below. Student User data will not be used to create marketing profiles for student Users or to send students marketing and promotional communications.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

‍For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Websites; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

‍With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

‍To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with our business partners and other third parties for our lawful business purposes, including to analyze and improve the Websites and promote our business.

‍Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

Technical operation. To allow the technical operation of the Websites.
Functionality. To enhance the performance and functionality of our services.
Analytics. To help us understand user activity on the Websites, including which pages are most and least visited and how visitors move around the Websites, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. To provide this service, Google Analytics may collect certain information about you from your computer using cookies. You can learn more about Google Analytics and how it collects and processes data by visiting: www.google.com/policies/privacy/partners/. You can opt-out of the use of Google Analytics here: https://tools.google.com/dlpage/gaoptout?hl=en.

How We Share your Personal Information
We do not share your personal information with third parties without your consent, except we may share your personal information in the following circumstances or as described in this Privacy Policy:

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Websites (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose. For example, they are prohibited from using your information to market their own products to you.
Payment processors. Any payment card information you use to make a purchase on the Websites is collected and processed directly by our payment processor, Stripe, and we never physically receive or store your full payment card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your Payment Information in accordance with its own Privacy Policy available here: https://stripe.com/privacy.
Third-party platforms and social media networks. If you have enabled features or functionality that connect the Websites to a third-party platform or social media network (such as by logging in to the Websites using your account with the third-party, providing your API key or similar access token for the Websites to a third-party, or otherwise linking your account with the Websites to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Business transfers. In the event of a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution, we may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with such transaction. To the extent we merge with or are acquired by another entity that obtains student User personal information we collected pursuant to this Privacy Policy, we will seek to obligate such entity to the principles of the Student Privacy Pledge.

Your Choices
In this section, we describe the rights and choices available to all users.
Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account. If we receive any requests to exercise such rights with respect to personal information for which we act as a processor on behalf of an Enterprise Customer, and we are not able to directly accommodate such requests, we will forward such requests to the applicable Enterprise Customer (or otherwise follow the procedure we have agreed upon with the applicable Enterprise Customer). Enterprise Users may need to contact the Enterprise Customer to update information provided by the Enterprise Customer.
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Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at support@levelall.com. You may continue to receive service-related and other non-marketing emails.
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Cookies. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Websites and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Websites may not work properly.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites, mobile applications and services. The Websites may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security practices
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
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International data transfers
We are headquartered in the United States and store your personal information in the United States. If you are located outside of the United States, you understand that, by using the Websites or providing us with your personal information, your data will be transferred to the United States, where privacy laws may be different from or not as protective as those in your country.
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Children and Students
As a general rule, children are not allowed to use the Websites, and we do not collect personal information from them. We define “children” as anyone under 13 years old. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will comply with applicable legal requirements to delete the information. We encourage parents with concerns to contact us. For Enterprise Users, parents should contact the Enterprise Customer.

Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Websites. We may, and if required by law or other obligation will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Websites.

For example, as required under the Student Privacy Pledge, we will provide prominent notice on the Website to Student Users after they log-in of any material changes to this Privacy Policy and allow them to choose before their personal information is used in a materially different manner than the initial version of the Privacy Policy.
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Unless otherwise required by applicable obligations, any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Websites (or as otherwise indicated at the time of posting), and your continued use of the Websites after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us
Please direct any questions or comments about this Policy or privacy practices to support@levelall.com. You may also write to us via postal mail at:
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Level All
Attn: Legal – Privacy
152 W. 57th St. 19th Floor
New York, NY 10019