Last Updated: April 15, 2022

This Privacy Policy describes how Inspira Education Group, Inc. and its related affiliates, doing business as Inspira Advantage, (“Inspira”, “we”, or “us”) collect, store, use and share personal information that we collect through our application, website and any other sites or services that link to this Privacy Policy (collectively, the “Services”).

Personal information we collect

Information you provide to us:

Contact and account information, such as your first and last name, email and mailing addresses, phone number, and date of birth.
Personal background, such as resumes, achievements, letters of recommendations, and essays that you submit to us.
Payment and transaction information, such as the Services you purchase and payment card information, which is processed by our payment service provider.
Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us online, or when you provide testimonials to us.
Usage information, such as information about how you use the Services and interact with us.
Marketing information, such as your preferences for receiving communications about our activities 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 you provide to admissions counselors and consultants. You may provide information to an admissions counsellor or consultant through our Services, including information about your background, experience, beliefs, and goals to assist you with your application for admission.

Automatic data collection. We and our service providers may automatically log information about you through the use of cookies and other local storage technologies. This information includes:

Device data, such as the manufacturer and model of the device, operating system, IP address (including the location associated with your IP address or internet connection), unique identifiers, and browser you are using.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

For more information on how we use cookies and other local storage technologies, please visit our Cookie Notice.

How we use your personal information

To operate our Services:

Provide, operate, maintain, secure and improve our Services
Process transactions initiated by you and send you notices about your transactions
Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages
Resolve disputes, collect fees, and troubleshoot problems
Understand your needs and interests, gather feedback, and personalize your experience with our Services and our communications
Verify your identity
Respond to your requests, questions and feedback

For research and development, including to analyze and improve the Services and to develop new products and Services, including by studying use of our Services.

Marketing and advertising, including sending you newsletters and promotions, as permitted by law, and engaging advertising partners, including third party advertising companies and social media platforms, to show you relevant interest-based advertising online. We also use information you provide, with your permission, for testimonials and other promotional content.

Compliance and protection, including to:

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims), including for health and safety purposes;
Audit our internal processes for compliance with legal and contractual requirements and internal policies; and
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How we share your personal information

Service providers. We share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Services (such as hosting, analytics, email delivery, and marketing, including delivering direct mail campaigns).

Advertising partners. We may share your personal information with third party advertising companies, including for the interest-based advertising purposes described above.

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. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with 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.

Admissions counselors

If you apply to serve as an admission counselor or consultant on the Services, we collect information , such as your credentials, background, experience, and any other information you submit. We also collect information such as your Social Security Number and bank account details to facilitate payments through our Services. We use this information to provide the Services to you and to enable you to connect with and assist students through the Services.

Your choices

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 contacting us at privacy@inspiraadvantage.com.

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 privacy@inspiraadvantage.com. You may continue to receive service-related and other non-marketing emails.

Online tracking opt-out. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.

Use the following links to learn more about how to control cookies and online tracking through your browser:

Firefox; Chrome; Microsoft Edge; Safari

Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising:

Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

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” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Security practices

We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

Children

We do not knowingly collect information from children under 13 years of age. If we learn that we have collected personal information through the Services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

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 our Services. We may 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 our Services.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on our Services (or as otherwise indicated at the time of posting).

How to contact us

Please direct any questions or comments about this Policy or privacy practices to privacy@inspiraadvantage.com.

Additional information for users located in California

This section applies only to California residents. For purposes of this section, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. The CCPA grants individuals whose information is governed by the CCPA the following rights:

Information. You can request information about how we have collected and used your personal information during the past 12 months. We have made this information available to California residents without having to request it by including it in this Privacy Policy.
Access. You can request a copy of the personal information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the personal information that we have collected from you.
Opt out of sale of your personal information. We do not sell personal information. Like many businesses, we use services that display interest-based ads to users around the web. We offer instructions on how to limit online tracking in the “Online tracking opt out” section above.

You are entitled to exercise the rights described above free from discrimination.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

How California residents can exercise their rights

You may exercise your California privacy rights described above as follows:

Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:

Calling us at +1-800-991-8924
Emailing privacy@inspiraadvantage.com

Right to opt out of sale of personal information. We offer instructions on how to limit online tracking in the “Online tracking opt-out” section above.
Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

Residents of the European Economic Area, United Kingdom, and Switzerland

This section applies only to individuals in the European Economic Area (including the Member States of the European Union, Iceland, Liechtenstein and Norway) the United Kingdom, and Switzerland.

Controller. Inspira is the controller of your personal information. You can find our contact information in the “Contact Us” section above.

Legal Bases for Processing. The specific purposes for which we process your personal information and the legal bases we rely on for the processing are listed below.

Purpose

Legal Basis For Processing

Service delivery

Processing is necessary to perform the contract governing our provision of our Services or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, [or if we provide the Services pursuant to a contract with your employer or another third party], we process your personal information based on our legitimate interest in providing the services you access and request.

Service improvement and development

Processing is necessary for our legitimate interests in improving and developing our service offerings. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Marketing and advertising

We process personal information for our legitimate interests in promoting and expanding our business, provided that these interests are not overridden by the impact on you. Where applicable, if you choose to subscribe to our delivery of direct marketing, the legal basis for this is your consent, which you may withdraw at any time.

Compliance and protection

Processing for these purposes is based on our legitimate interests and the legitimate interests of third parties, provided that these interests are not overridden by the impact on you. Where we process personal information as required by the law of the country in which you reside, our obligation to comply with legal requirements.

Your Rights. You have the following rights in relation to your personal information under certain circumstances and subject to any applicable exceptions:

Access. You may request information about, or to have access to, your personal information that we process.
Rectification: You may request to update personal information that is inaccurate or incomplete.
Erasure: You may ask us to delete or remove certain personal information that is no longer necessary for the Services where we have no other grounds to retain such information.
Restriction: You may ask us to restrict or ‘block’ the processing of your personal information in certain circumstances, such as where you contest the accuracy of the data or object to us processing it.
Portability: You may request access to some of your personal information in a structured, commonly used and machine-readable format.
Objection: You may object to our reliance on legitimate interests as the basis for processing your personal information that impact your rights.

Please see the “Contact Us” section above for information on how to exercise your rights. We may request specific information from you to help us confirm your identity and process your request. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Information Processing in the U.S. Inspira is based in the U.S. The U.S. may have data protection laws less stringent than or otherwise different from the laws in effect in the EEA, UK, or Switzerland.