Privacy Statement

GetSet Learning, LLC and our affiliated companies ("GetSet" or "we") are committed to protecting your privacy. This Privacy Statement (the "Statement") covers your use of our website, our mobile applications, and other tools we use to provide GetSet's services (together, the "Platform"). Please read this Statement to understand the following:

• Effectiveness of this Statement
• What information we collect
• How we use the information we collect
• How we share the information we collect
• Your rights and choices
• Security and other important information

In addition to this Privacy Statement, we encourage you to review our GetSet Privacy FAQ for detailed information about who can see your information and how to control it. Importantly, the Privacy FAQ will explain that:

• You always have control over the information you share on GetSet.
• GetSet is sponsored by your school or organization, so your school or organization can see most of the information you share on GetSet.
• Other than sharing with your school or organization, we never sell or transfer your information to third parties who are not our service providers using the information at our direction.

Effectiveness of this Statement

This Privacy Statement is effective as of December 2021. This Statement may be changed from time to time. We encourage you to review this Statement occasionally to stay informed about our privacy practices. Any changes to this Statement will become effective upon posting. When we change this Statement, your continued use of the Platform signifies your acceptance of the updated Privacy Statement.

California residents, please review the California Privacy Statement for information about certain legal rights.

This Privacy Statement is incorporated into and subject to the GetSet Terms and Conditions. If you do not agree to the terms of this Privacy Statement, please do not provide us with any information and do not use the Platform. By using the Platform and voluntarily providing your information to us, you consent to the collection and use of such information as described in this Privacy Statement.

In addition, by using the Platform and providing us your information you explicitly acknowledge and agree to the transfer and storage of your information to the United States and to other jurisdictions worldwide.

What information we collect

GetSet collects: (i) information you give us, (ii) information we automatically collect, and (iii) information from third party sources.

Information you give us

Account information. When you register for a GetSet account, you are required to provide certain personal information like your name, email address, and school or organization.

Profile information. You may opt to provide additional profile information in order to use certain features of the Platform. Profile information can include profile pictures, personal information about yourself and your experiences, interests, posts, messages, and activity. You are responsible for choosing which information you provide to GetSet.

Communications with GetSet. Whenever you contact GetSet, whether via the Platform, email, phone, or other methods, we collect information you provide so that we can communicate with you, such as your name, email address, phone number, and the content of your messages.

Referral information. You may choose to let other individuals know about GetSet through referral features. When you use this feature, we collect information required for communicating with those individuals, such as their name and email address.

Information we automatically collect

We automatically collect certain information when you use the Platform, even if you have not registered for a GetSet account or logged in.

Cookies. We use cookies to provide you with a faster and more personalized experience on the Platform and to better understand user behavior through analytics as described below. Most web browsers automatically accept cookies. You may change your browser settings to remove or reject cookies, but doing so will affect how the Platform works for you. We do not store personally identifiable information in cookies.

Analytics and technical information. We use Google Analytics and other service providers to collect information regarding user behavior and demographics on the Platform. These services use cookies and other technology to collect information such as your web browser, operating system, device, and state of residence. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners. You can opt out of Google’s collection and processing of data generated by your use of the Platform by going to http://tools.google.com/dlpage/gaoptout. We do not connect information gathered using third party analytics to your personally identifiable information, unless that information is provided by you (e.g. by logging in), or by an approved third party as described below.

Web beacons and similar technology. Web beacons are digital images that we use to learn how users engage with our emails and other aspects of the Platform. We use web beacons to collect whether you open or act on our emails.

Information we collect from third party sources

Your school or organization. Your school or organization may provide us with directory information, such as your name and email address, and other personal information, such as your enrollment status or program of study. We use this information within the bounds of our contract with your school or organization to contact you about the Platform, or to verify your identity.

Referrals. We may receive your information from other individuals who have referred you to GetSet. When such individuals use our referral feature, we collect information required for communicating with you, such as your name and email address.

How we use the information we collect

We collect, retain, and use the information we collect for legitimate business purposes only, including, without limitation, the following:

• To provide the Platform's services to you and other users;
• To improve the Platform, including by personalizing your experience on the Platform;
• To monitor usage and performance of the Platform;
• To provide customer support;
• To send you information about GetSet, including service, support, technical, and administrative messages; and targeted marketing, surveys, and promotions;
• If you indicate interest in a school or organization, to provide you with information about that school or organization;
• If you provide us or our service providers information relating to other people via a referral feature, to send referral invitations to those individuals;
• To enforce our Terms and Conditions;
• To comply with applicable laws, regulations, rules, and law enforcement or government requests;
• And to protect the rights, property, health or safety of GetSet, our users, and others.

How we share the information we collect

GetSet is about connecting people and sharing advice, information, and experiences. All posts, profile information, and other information you provide on the Platform may be shared as described in this Privacy Statement. Information you share can also be removed by GetSet if it violates the GetSet Terms and Conditions.

With other GetSet users

You may choose to post or share information on the Platform (including through your profile). When you post or share information, your information is shared via the Platform, including our website, mobile apps, emails, push notifications, and other media.

Your school or organization’s community. When you post or share information on the Platform, your information is shared with other GetSet users within your school or organization’s community.

GetSet global community. When you register for a GetSet account, you may have the option to "opt-in" to sharing your posts and information with the GetSet global community, which means your information will be shared with GetSet users from other schools or organizations. When you opt-in to this sharing, your information cannot be viewed or accessed by the administrators of such other schools or organizations.

Making information "Private"

When you post or share information on the Platform, you may have the option to make that post or information "private". To make a post "private", select the checkbox prior to clicking "post", edit the post's settings after posting. You can make other information "private" in your Account settings. Making a post "private" will hide your post or information from other GetSet users. However, please note that selecting the "private" feature will not hide the post or information from your school or organization. In other words, your school or organization will still be able to view a post or information you share on the Platform, even if your post or information is "private".

With your school or organization

Access to the Platform is sponsored by your school or organization. In certain instances, your GetSet account may be associated with one or more schools or organizations with which you are involved.

Administrators of your school or organization. Any information you provide on the Platform is shared with, and may be retained and used by, administrators (e.g., faculty, employees, instructors, advisors, and other staff members) of your school or organization that sponsor your GetSet account. Information you provide on the Platform may be used by your school or organization to evaluate your use of the Platform in addition to supporting GetSet in providing the Platform. Please contact your school or organization’s administrators for more information about how it uses and shares your information.

Non-GetSet users (students, prospective students, and alumni). In addition, your school or organization may instruct us or choose to share your posts or information with people who are students, prospective students, and alumni of your school, but who are not yet GetSet users within your community.

With service providers

We engage certain vendors and third party service providers to help us provide and make the Platform available. As a result, these vendors and third party service providers may collect and/or have access to your information. These vendors and third party service providers are only allowed to use your information to support us in providing and making the Platform available, which means that they cannot use or share your information outside the bounds of their engagement with us.

With your consent

You may direct us to share or consent to us sharing your information in response to a request from GetSet, such as authorizing us to share a post you wrote on our Platform or social media. In these contexts, we never post real names, and we completely anonymize any references that could be used to identify you.

Anonymized or aggregated data

GetSet may share your information with third parties, including those not affiliated with your school or organization, in an anonymized or aggregated format, which means that GetSet will remove your personally identifying information, such as your profile photo and last name, from the information.

Business transfer

GetSet may, in the future, sell or otherwise transfer some or all of its assets to a third party in connection with a business transaction, including a merger or sale of our business or assets, a reorganization, or insolvency or bankruptcy proceeding. Your information may be disclosed to any potential or actual third party purchasers of such assets and/or may be among those assets transferred.

Legal and compliance

GetSet will comply with all court orders we may receive, including as required to ensure the safety of people who use GetSet. We may also share information when we have a good faith belief it is necessary to prevent fraud or other illegal activity, to prevent imminent bodily harm, or to protect others. This may include sharing information with your school administration or faculty, other companies, lawyers, courts, or other government entities. Similarly, we will disclose information we collect, including personally identifiable information, when required to do so by law, or may disclose such information in response to a request from a law enforcement agency or authority.

Your rights and choices

Privacy settings

You can control how your information is shared through your privacy settings or by deleting your information. However, note that people may have captured and retained, by screenshot or otherwise, information which has been unshared or deleted. Similarly, note that other people may capture your information and share it beyond the original intended audience, by email, social media, or otherwise. GetSet is not responsible for any third party seeing information that was captured during the time it was shared and then retained and/or reshared by a third party, including information that was later unshared or deleted.

Updating your information

We strive to maintain the accuracy of any information that may be collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. It is your responsibility to ensure that such information is accurate, complete, and up to date. You may view and make changes to your information on your profile page and in your account settings. Please note, in certain instances, changes, modifications or updates to your information must be directed to and/or approved by your school or organization.

Communications preferences and closing your account

If you have a GetSet account:

• You can control how we contact you and what we contact you about in your account settings.
• You may opt out of receiving communications from us or remove your information from the Platform by emailing us at privacy@getset.com. If you would like to remove your information from the Platform, please email us with the subject line "Close Account."

Consequences of not providing information

You may choose not to provide us with your information. However, choosing not to provide certain requested information may prevent you from accessing and using certain services offered by GetSet.

Cookies and similar technologies

Most browsers automatically accept cookies by default, but you can adjust your device and/or browser settings to delete and/or block some or all cookies, or provide notifications when you receive a new cookie. Consult the "Help," "Tools," or "Preferences" menus on your browser, or the documentation for your device, for more information about how to do this. Please note, however, that blocking or deleting certain cookies may negatively affect your user experience. If you wish to opt out of Google Analytics tracking, visit https://tools.google.com/dlpage/gaoptout. You may also disable tracking for certain analytics providers by removing or blocking related cookies or similar technologies.

Your California privacy rights

California residents, please review the California Privacy Statement for information about certain legal rights.

Your Nevada privacy rights

Nevada residents have the right to request that their personal information not be sold (as defined under applicable Nevada law), even if their personal information is not currently being sold. If you are a Nevada resident and would like to exercise this right, please send an email to privacy@getset.com with your request.

Security

Because security is important to both GetSet and you, we make reasonable efforts to ensure the security of our systems. Although by default we limit access to information and certain pages and features of the Platform, please be aware that no security measures are perfect or impenetrable and we cannot and do not warrant or guarantee that your information is secure or will not be viewed by unauthorized people.

If you have a GetSet account, you should not share your password with anyone. In addition, if you suspect unauthorized access to your account or your information, it is your responsibility to contact GetSet immediately by emailing us at help@getset.com. GetSet personnel will never ask you to provide your password in written or electronic communications or over the phone.

Important information

Children

GetSet does not permit children under 13 years of age to use the Platform without their parent or guardian's express consent and approval. By using the Platform, you represent that you are not under 13 years of age.

Third-party websites and services

As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business. When you access these third-party services, you leave our Platform, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk. This Privacy Statement does not apply to any third-party services; please refer to the privacy notices or policies for such third-party services for information about how they collect, use, and process personal information.

Do Not Track

We use analytics systems and providers that process information data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s "do not track" signal or similar mechanisms.

Note, however, that you may find information about how to opt out of Google Analytics and/or block or reject certain tracking technologies in the section captioned "Your rights and choices" in our Privacy Statement.

Contact

If you need help using GetSet, you can always reach us at help@getset.com.

Questions regarding this Privacy Statement should be directed to GetSet Legal at privacy@getset.com. GetSet may also be contacted directly at the following address:

      GetSet Learning, LLC
      332 S Michigan Avenue
      Suite 121
      Chicago, IL 60604
    

California Privacy Statement

This California Privacy Statement ("California Statement") supplements the Privacy Statement and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you"). GetSet Learning, LLC and our affiliated companies (collectively, "GetSet", "we", "us", "our") adopted this California Statement to comply with California privacy laws, including the California Consumer Privacy Act ("CCPA"). Any terms defined in the CCPA and not defined here have the same meaning when used in this California Statement.

I. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Information"). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Information. To the extent this data is stored or associated with Personal Information, it will be treated as Personal Information; otherwise, the data is not subject to this notice.

Categories of Personal Information

Within the last twelve (12) months, we have collected the following categories of Personal Information:

1. Identifiers. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
2. Personal Details. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)), such as physical characteristics or description that you choose to share via the Platform (including your profile), telephone number, education information, or employment information that you choose to share via the Platform (including your profile).
3. Demographic Information. Characteristics of protected classifications under California or federal law (e.g., gender).
4. Usage Data. Internet or other electronic network activity information, including, but not limited to, information regarding your interactions with the Platform, including our website, mobile apps, emails, or push notifications.
5. Geolocation data.
6. Visual Information. Visual or similar information, such as your profile picture.
7. Professional Information. Professional or employment-related information, such as your school or organization.
8. Inferences. Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We will not collect additional categories of Personal Information other than those categories listed above. If we intend to collect additional categories of Personal Information, we will provide you with a new notice at or before the time of collection.

Use of Personal Information

We collect and process your Personal Information for the following business and commercial purposes:

• To provide the Platform's services to you and other users;
• To improve the Platform, including by personalizing your experience on the Platform;
• To monitor usage and performance of the Platform;
• To provide customer support;
• To send you information about GetSet, including service, support, technical, and administrative messages; and targeted marketing, surveys, and promotions;
• If you indicate interest in a school or organization, to provide you with information about that school or organization;
• If you provide us or our service providers information relating to other people via a referral feature, to send referral invitations to those individuals;
• To enforce our Terms and Conditions;
• To comply with applicable laws, regulations, rules, and law enforcement or government requests;
• And to protect the rights, property, health or safety of GetSet, our users, and others.

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice.

Sources of Personal Information

We collect Personal Information from the following categories of sources:

1. From You. We collect information from you when you register for a GetSet account, provide additional profile information, contact us, or subscribe or opt in to our newsletter, alerts, or other communications.
2. Your School or Organization. Your school or organization may provide us with directory information, such as your name and email address, and other personal information, such as your enrollment status or program of study.
3. Referrals. We may receive your information from other individuals who have referred you to GetSet. When such individuals use our referral feature, we collect information required for communicating with you, such as your name and email address.
4. Operating Systems and Platforms. We obtain your information through your use of the GetSet Platform. For example, we automatically collect information relating to the computer or device you are using when you access or use the Platform, such as your IP address, the type of browser and operating system you are using, and your device and browser settings.
5. Service Providers. We engage certain vendors and third party service providers to help us provide and make the Platform available. As a result, these vendors and third party service providers may collect and/or have access to your information.

Sharing of Personal Information

Within the last twelve (12) months, we have shared the following categories of Personal Information for a business purpose with the following categories of third parties:

• Identifiers: Your School or Organization, GetSet Users (which may include users within your school or organization’s community or within the GetSet global community)
• Personal Details: Your School or Organization, GetSet Users
• Demographic Information: Your School or Organization, GetSet Users
• Usage Data: Your School or Organization, GetSet Users
• Geolocation Data: Your School or Organization, GetSet Users
• Visual Information: Your School or Organization, GetSet Users
• Professional Information: Your School or Organization, GetSet Users
• Inferences: Your School or Organization

Please contact your school or organization’s administrators for more information about how it uses and shares your information.

II. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, known as the "Shine the Light" law, permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. All GetSet users, regardless of their state of residence, are welcome to make such requests of us. Requests may be made only once a year by sending an email to privacy@getset.com, and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.

The CCPA provides California residents with the following rights:

1. Right to Know: You have the right to request that we disclose certain information to you about the Personal Information we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:
   • The categories of Personal Information collected about you;
   • The categories of sources from which we collected your Personal Information;
   • The categories of Personal Information that we have sold or disclosed about you for a business purpose;
   • The categories of third parties to whom your Personal Information was sold or disclosed for a business purpose;
   • Our business or commercial purpose for collecting or selling your Personal Information; and
   • The specific pieces of Personal Information we have collected about you.
2. Data Portability: You have the right to request a copy of Personal Information we have collected and maintained about you in the past 12 months.
3. Right to Deletion: You have the right to request that we delete the Personal Information we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information if it is necessary for us or our service providers to:
   • Complete the transaction for which the Personal Information was collected, 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 our business and you.
   • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
   • Debug to identify and repair errors that impair existing intended functionality.
   • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
   • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
   • 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 the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
   • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
   • Comply with a legal obligation.
   • Otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
4. Right to Opt-In to Financial Incentives: You have the right to opt-in to financial incentives program. You also have the right to opt-out at any time. However, we do not offer financial incentives at this time.

5. Right to Opt-Out/In: You have the right to opt-out of the sale of your Personal Information. You also have the right to opt-in to the sale of Personal Information. However, we do not "sell" your Personal Information.

   We do not and will not knowingly sell the Personal Information of minors under the age of 16 without affirmative authorization

6. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:
   • Deny you goods or services.
   • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
   • Provide you a different level or quality of goods or services.
   • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

You may choose not to provide us with your information. However, choosing not to provide certain requested information may prevent you from accessing and using certain services offered by GetSet.

III. SUBMITTING A VERIFIED CONSUMER REQUEST

To exercise your Right to Know, Data Portability, and Right to Delete, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so.

To exercise your California privacy rights described above, please submit a verifiable request to us by:

• Submitting the form on our Your California privacy rights page.
• Emailing us at privacy@getset.com.

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for Right to Know or Data Portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. Given the nature and sensitivity of the Personal Information that we collect and retain, we will need to verify your identity with your full name (as appears in your school/organization record), primary school/organization email address associated with your account, and student or employee ID number. For certain requests, the information and confirmation will be sent only to the email address on record.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

Consumer Request by an Authorized Agent

If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require that an email be sent to privacy@getset.com along with all of the below items:

• To verify the authorization to request on behalf of a California resident, one or more of the following: (1) California Secretary of State authorization, (2) proof that the California resident gave permission to submit the request, or (3) proof of power of attorney signed, written permission from the California resident or power of attorney.
• Sufficient information to verify the authorized agent’s identity, depending on the nature of the request.
• Sufficient information to identify you. We may require that you directly confirm to us your identity and that you provided the authorized agent with permission to submit the request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the request’s identity or authority to make the request.

We will acknowledge receipt of the request within ten (10) business days of its receipt. We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability requests, we will provide the responsive information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, 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.

Do Not Track

We use analytics systems and providers that process Personal Information about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s "do not track" signal or similar mechanisms.

Note, however, that you may find information about how to opt out of Google Analytics and/or block or reject certain tracking technologies in the section captioned "Your rights and choices" in our Privacy Statement.

IV. MODIFICATIONS AND UPDATES TO THIS CALIFORNIA STATEMENT

This California Privacy Statement is effective as of December 2021. This California Statement may be changed from time to time. We encourage you to review this California Statement occasionally to stay informed about our privacy practices. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this California Statement, such as by posting a notice on the Services or sending you an email. Any changes to this California Statement will become effective upon posting. When we change this California Statement, your continued use of the Platform signifies your acceptance of the updated California Privacy Statement.

V. ADDITIONAL INFORMATION AND ASSISTANCE

Questions regarding this California Statement should be directed to GetSet at privacy@getset.com. GetSet may also be contacted directly at the following address:

      GetSet Learning, LLC
      332 S Michigan Avenue
      Suite 121
      Chicago, IL 60604
    

For more information about how users with disabilities can access this California Statement in an alternative format, please contact us at privacy@getset.com.