COLLEGE ADMISSIONS CHATBOT PRIVACY POLICY

Effective Date: May 7, 2025

We at Prepory Coaching Group, LLC (“Prepory,” “we”, “us,” “our”). We have created this privacy policy (“Chatbot Privacy Policy”) to describe our information collection and use practices in connection with the use of our interactive College Admissions Chatbot service (the “Service”). This Chatbot Privacy Policy is a supplement to our general privacy practices, such as information collected through our website or our general online services; those practices are governed by our general Privacy Policy, which you can access at https://prepory.com/privacy-policy.

Please read this Chatbot Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use, and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and internationally, and we are responsible as “controller” of that personal information for the purposes of those laws.

Before using the Service and submitting any personal information to us, please review the Chatbot Privacy Policy carefully. By using the Service, you are agreeing to the terms of this Chatbot Privacy Policy as well as the provisions of the Prepory Terms of Use located at prepory.com/terms-of-use.

1. What Information Do We Collect About You?

To use the Service, we may ask you for information including your first name, last name, and e-mail address. We also collect personal data from you that you provide in the input of our chatbot Service (“Content”), including text prompts, files, images, and audio. When you use the Service, we may also receive technical information about your visits, including your log data, usage data, location information, and device information. We also use cookies to help optimize your current and future experience with the Service as well as to remember your settings and account configuration. Cookies allow our Service to recognize you and your prior inputted information if you return to the Service shortly after exiting. Cookies can be turned off via your browser settings if you so choose. However, if you turn your cookies off, some features of the Service may not function properly and the Service may not remember your prior inputs entered into the Service.

More information about the information we collect is provided below:

Categories of Personal Information
Identifiers, such as your name, contact details, IP address, and other device identifiers
Commercial information, such as your transaction history
Network activity information, such as Content and how you interact with the Service
Communication information, such as your contact information when you send us email
Geolocation data, such as the general area from which your device accesses our Services based on information like its IP address, or precise location information you choose to provide

If you do not provide personal information required to provide the Service to you, it may delay or prevent us from providing the Service to you.

We collect personal information from the following categories of sources:

  • You, directly in person, by entering prompts into the Service
  • Internet service providers
  • Operating systems and platforms
  • Social networks
  • Cookies on our website

Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

  • To comply with our legal and regulatory obligations
  • For the performance of our contract with you or to take steps at your request before entering into a contract
  • For our legitimate interests or those of a third party –or–
  • Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for Our reasons
To provide the Service to you For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Prepory For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies. To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our product range or other efficiency measures For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating customer records For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our Service to:

  • Existing and former customers
  • Third parties who have previously expressed an interest in our services
  • Third parties with whom we have had no previous dealings
 For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.

We routinely share personal information with:

  • Our affiliates, including companies within the Prepory group.
  • Service providers we use to help deliver our Service to you, such as the AI APIs that we use to help operate the Service.
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts
  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
  • Our insurers and brokers
  • Our banks

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will keep your personal information while you have an account with us or while we are providing the Service to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf
  • To show that we treated you fairly –or–
  • To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Right Description
Disclosure of Personal Information We Collect About You You have the right to know, and request disclosure of:

  • The categories of personal information we have collected about you, including sensitive personal information
  • The categories of sources from which the personal information is collected
  • The categories of third parties to whom we disclose personal information, if any –and–
  • The specific pieces of personal information we have collected about you

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–
  • Provide the personal information to you more than twice in a 12-month period
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose You have the right to direct a business that sells or shares personal information about the consumer to third parties not to sell or share the consumer’s personal information. We do not sell and will not sell your personal information as that term is commonly understood. We also do not sell and will not sell your personal information, as that term is defined by the CCPA. We do not share your personal information as that term is defined in the CCPA.
Right to Limit Use of Sensitive Personal Information You have the right to direct a business to limit the use of the consumer’s sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services and certain other limited uses as described in the CCPA and applicable regulations. We do not use or disclose sensitive personal information for purposes other than those purposes specified in Section 7027, subsection (m) of the California Consumer Privacy Act Regulations. If we begin using or disclosing your sensitive personal information outside of those purposes, then we will provide you with the option to limit our use or disclosure through a clear and conspicuous link on our internet homepage.
Right to Deletion Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records –and–
  • Delete your personal information from our records –and–
  • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort

Please note that we may not delete your personal information if it is reasonably necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us
  • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes
  • Debug to identify and repair errors that impair existing intended functionality
  • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law
  • Comply with the California Electronic Communications Privacy Act
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
  • Comply with an existing legal obligation –or–
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Right of Correction If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation We will not discriminate against you for exercising your rights under the CCPA. Unless otherwise permitted by the CCPA we will not:

  • Deny you goods or Service.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide a different level or quality of goods or services.
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Right Description
Right to Be Informed The right to know or be notified about the collection and use of your personal information
Right to Access The right to be provided with a copy of your personal information (the right of access)
Right to Rectification The right to require us to correct any mistakes in your personal information
Right to be Forgotten The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object The right to object:

  • At any time to your personal information being processed for direct marketing (including profiling)
  • In certain other situations to our continued processing of your personal information, e.g., processing carried out for our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the EU General Data Protection Regulation.

If you would like to exercise any of your rights as described in this Chatbot Privacy Policy, you can do so by emailing us at info@prepory.com.

  • Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
  • We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
  • Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

Information may be held at our offices and those of our affiliates, third-party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”

To deliver services to you, it is sometimes necessary for us to share your personal information outside the EEA, e.g.:

  • With our offices outside the EEA
  • With your and our service providers located outside the EEA
  • If you are based outside the EEA –or–
  • Where there is an international dimension to the services we are providing to you

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We hope that we can resolve any query or concern you raise about our use of your information. The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

This Chatbot Privacy Policy is effective as of the date stated at the top of this Chatbot Privacy Policy. We may change this Chatbot Privacy Policy from time to time and will post any changes on the Service as soon as they go into effect. By accessing the Service or using the Service after we make any such changes to this Chatbot Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Chatbot Privacy Policy on a regular basis.

Please contact us at info@prepory.com if you have any questions about this Chatbot Privacy Policy or the information we hold about you.