Privacy Policy

Effective Date: December 14, 2024

Find Your Future, Inc., a Delaware corporation, and its affiliates (collectively, "we," "our," or "us"), provides this Privacy Policy (the "Policy") to inform you of our policies and procedures regarding the collection, use, and disclosure of personal information we receive via our website (the "Site") and through the use of any services provided by us through the Site (the "Services"). This Privacy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. Your use of the Site and/or any of our Services following any such notice will signify and constitute your consent to and acceptance of such revised Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalized terms used herein have the same meanings as in our Terms of Service.

1. Information We Collect. Our primary goals in collecting information are to provide and improve our Service, to administer your orders, to communicate with you, and to enable users of the Site to enjoy and easily navigate the Site. When you wish to contact us, create an account on the Site, edit account details, purchase products or services via the Site, use any of our Services, or when you join our mailing lists, we will ask you for certain Personal Information. When we refer to your "Personal Information" in this Privacy Policy, we mean information that identifies, describes, relates to, references or is capable of being associated with, or could reasonably be linked, directly or indirectly, to you. We may also collect other information generated when you use our Site or Services that is not linked or otherwise associated with you, and such information is not subject to the terms of this Privacy Policy. Depending on how your use our Site and/or our Services, we may directly collect the following types of Personal Information from you:

• Your internet service provider's address, your internet protocol or IP address, device ID, the web page from which you accessed our Sites, your web browser software, the type of handheld or mobile device used to link to the web page, and the language settings on your web browser;
• Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories;
• Data about the webpages you visit, including without limitation web browser specifications, websites visited before accessing our Site, and websites visited after leaving our Site;
• A record of your activity and interactions while visiting or using our Site, including the existence or types of data you may upload or the terms you search;
• Data about your device and nearby networks, including internet connection information, computer equipment information, regional and language settings;
• Data about the performance of our website or mobile apps;
• "Cookies" or other common tracking methods of different types to recognize your computer (please see the Cookies section below for description of what Cookies are and how they are used); and
• Web beacons, match scripts, pixel tags, or similar technologies that allow us to know information such as whether a particular web page was visited, an e-mail opened, links in the email accessed, if the advertisements on our Sites or other sites were useful or beneficial to the user(s), or other information that may help us improve your experience.

We may also collect any personal information that you provide or input on our Sites, including but not limited to:

• your name, e-mail address, mailing address, phone number;
• any information you provide in a college survey;
• any data you provide in the context of a job application with us.
• any data you provide in the context of your use of our Preferred Partners
• Any other information you provide to us through our Site.

2. Information from Social Networking Sites. Our Service may include interfaces that allow you to connect with social networking sites (each an "SNS"). If you connect to a SNS through the Site, you authorize us to access, use, and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use, and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

3. Information Automatically Collected. When you visit our Site, some information is automatically collected. For example, when you visit our Site your computer's operating system, Internet Protocol (IP) address, access times, browser type and language, and the Site you visited before our Site are logged automatically ("Usage Information"). We also collect information about your usage and activity on our Site, including but not limited to the following:

A. Cookies

We may automatically collect information using "cookies." Cookies are small data files stored on your hard drive by a Site. Among other things, cookies help us improve our Site and your experience. We use cookies to see which areas and features are popular and to count visits to our Site. We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognize your computer or mobile device when it visits other sites. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit https://www.allaboutcookies.org/ and, if you are in the United Kingdom ("UK") or European Union ("EU"), https://www.youronlinechoices.com/uk/.

B. Web Beacons

We may collect information using Web beacons. Web beacons are electronic images that may be used on our Site or in our emails. We use Web beacons to deliver cookies, count visits, understand usage, and to tell if an email has been opened and acted upon.

C. Local Shared Objects

We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control or to display content based upon what you view on our Site to personalize your visit. Third party partners provide certain features on our Site and Services and display advertising based upon your Web browsing activity using Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and way in which data is stored. Cookie management tools provided by your browser usually will not remove Flash cookies. To limit the websites that can store information in flash cookies on your device, you can use the Adobe Settings Manager available at: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

D. Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to better assist us in understanding how the Site is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Site, including your computer's IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Site, compiling reports on Site activity for our use, and providing other services relating to Site activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of the Site. The use of cookies by Google Analytics is covered by Google's Privacy Policy, available at: https://policies.google.com/privacy.

4. Information Collected from Other Third Parties. We may receive your Personal Information from third party business partners, such as social media sites, ad networks, and analytics providers. We may also receive your Personal Information from others that refer you to our Sites and/or Services.

5. Linked Accounts. To the extent that you share your account or "link" your account with other person or user, you understand that that you and all persons you invite to join your account shall create their own usernames and passwords. Those persons with whom you may will be able to view your following information:

• Your first name and last name;
• Your relationship (student, parent, etc.);
• Your email address;
• Your college survey results; and
• The information you shared in your survey responses, including but not limited to, financial information.

6. Use of Information. We use your Personal Information collected for the purposes described in this Policy. Specifically, we may use your Personal Information to:

• operate and improve our Site and Services;
• understand you and your preferences to enhance your experience;
• track, collate, and analyze your use of our Site and Services;
• process and deliver contest entries and rewards;
• respond to your comments and questions and provide customer service;
• provide and deliver products and Services you request;
• to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• facilitate your participation in participate in surveys, promotional offers, contests or sweepstakes;
• communicate with you about new contests, promotions, rewards, upcoming events, and other news about products and Services offered by us and our selected partners;
• link or combine it with other Personal Information we get from third parties, to help understand your needs and provide you with better service;
• authorize the use of debit card and check transactions, order fulfillment, service promotions; and
• engage in other services that you expressly request which require us to share your personal information.

7. Sharing of Information. We do not share your Personal Information with third parties except in the following circumstances:

• Affiliates and Subsidiaries. We may share your Personal Information with our affiliates and subsidiaries with the understanding that they will treat such information consistent with this Privacy Policy.
• Preferred Partners. We may share your Personal Information with our Preferred Partners with the understanding that they will treat such information consistent with this Privacy Policy.
• Third Party Service Providers. We may share your Personal Information with our third party vendors, consultants, and other service providers who work for us and need access to your information provide you with products, services, or information that you request. For example, we use Mailchimp (https://mailchimp.com/legal/privacy/) to facilitate our email communications.
• Other Third Parties. We may share your Personal Information with appropriate third parties if we believe it is necessary, in our reasonable discretion, to (i) comply with laws or to respond to lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (ii) protect the rights and property of us, our agents, customers, members, and others including to enforce our agreements, policies and terms of use; or (iii) in an emergency to protect the personal safety of us, our customers, or any person.
• Corporate Restructuring. We may share your Personal Information in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another entity.
• With Your Consent. We may share your Personal Information with third parties where you have provided consent to such sharing.

We may also share aggregated anonymous or de-identified information. When we use the term "anonymous data", we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create anonymous data from the Personal Information we receive about you and other individuals whose Personal Information we collect. Anonymous data might include analytics information and information collected by us using cookies. We make Personal Information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Services.

8. Payment Card Information. We do not collect, store, or process any payment card information. Instead, we rely on Stripe to facilitate any payment card transactions. For more information about Stripe's privacy practices, please see: https://stripe.com/us/privacy.

9. Email Opt-Out and Disabling Cookies.

A. Email Opt-Out

You may opt out of receiving promotional emails from us by following the instructions in those emails or sending a message with your request and the subject line "EMAIL OPT OUT REQUEST" to privacy@findyourfuture.net. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

B. Disabling Cookies & Other Similar Tracking Technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site and Services.

You may also remove certain tracking technologies and opt-out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance at https://youradchoices.ca/en/tools and the Network Advertising Initiative at https://optout.networkadvertising.org.

10. Third Party Sites and Links. Our Site and Services may contain links to third party sites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their sites, features or policies. Please read their privacy policies before you submit any data to them.

11. Children's Information. 

A. Users under Age 13

Our Site and Services are not directed children under the age of 13. If you are under 13, you may not access, attempt to access, or use our Site or Services. We do not knowingly collect or allow the collection of Personal Information via the Site or Services from persons under the age of 13, pursuant to applicable law and regulations. If we learn that we have collected the Personal Information of someone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information to us, you may contact us at privacy@findyourfuture.net and ask us to remove your child's Personal Information from our systems.

B. Users under Age 18

Personal information that has been provided to us through our Site by minors under the age of 18, can be deleted by sending an email requesting the deletion to privacy@findyourfuture.net. Please note that while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

12. Information Security. We take reasonable organizational, technical, and administrative steps to help protect Personal Information against loss, misuse, unauthorized access, or disclosure. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. As a result, by accessing the Site, any transmission of data is at your own risk and you agree to assume all risk in connection with data sent to us or collected by us.

13. Information Retention. We retain data only as long as necessary in light of the purpose(s) for which it was originally collected. Please note that we may retain your data for longer periods of time as necessary to comply with our legal obligations or respond to governmental authorities.

14. Your California Privacy Rights. If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth in this Policy. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:

• the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
• the names and addresses of the third parties that received the information; and
• if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized format that is not specific to you. To request this information, email a request at: privacy@findyourfuture.net.

Additionally, if you are a California resident, are under the age of 18, and you have posted content or information to our Site or Services, you can request that we remove content or information that you have posted to our Site or Services. Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by other individual). To make such a request, email privacy@findyourfuture.net.

Also, please note that we have not yet developed a response to browser "Do Not Track" signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to "Do Not Track" signals in light of industry developments or legal changes.

15. European Users' Rights. If you are located in the EU or Switzerland, you have certain rights with respect to your Personal Information. The following is a summary of those rights and additional information applicable to our collection and use of your Personal Information.

A. Data Controller

When you provide us with your Personal Information through the Site and/or our Services, we serve as a data controller. When we act as a data controller, we determine how your Personal Information will be utilized, in accordance with this Policy.

B. Legal Basis for Processing Information

• If you are located in the EU or Switzerland, we rely on several legal bases to process your Personal Information. These legal bases include where:
• The processing is necessary to perform our contractual obligations, such as to provide you with our Services;
• You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
• The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims; and
• The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing our Site and Services, marketing new features or products that may be of interest, and promoting safety and security as described above.

If you have any questions about or would like further information concerning the legal bases on which we collect and use your Personal Information, please contact us by emailing privacy@findyourfuture.net.

C. Rights Under the General Data Protection Regulation

If you are located in the EU or Switzerland, you have the following rights with respect to your Personal Information that we hold:

• Right of access. The right to obtain access to your Personal Information.
• Right to rectification. The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete.
• Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.
• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
• Right to portability. The right to portability allows you to move, copy, or transfer Personal Information easily from one organization to another.
• Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

If you wish to exercise one of these rights, please email us at privacy@findyourfuture.net. You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

D. Retention of Personal Information

When reserve the right to retain any Personal Information as long as it is needed to: (1) fulfill the purposes for which we collected the Personal Information; and (2) comply with applicable law.

E. Transfers of Personal Information

If you are located in the EU, the personal information we collect may be stored and processed in any country in which we or our affiliates, suppliers, third party electronic payment processors, and/or financial institutions or agents maintain facilities, including, but not limited to, the United States of America. YOU CONSENT TO ANY AND ALL PERSONAL INFORMATION YOU PROVIDE AND SUBMIT VIA THE SITE AND SERVICES BEING SENT TO THE UNITED STATES OF AMERICA. The United States of America has not sought nor received a finding of "adequacy" from the EU under Article 45 of the GDPR. We rely on derogations for specific situations as set forth in Article 49 of the GDPR. YOU ARE ALSO INFORMED THAT THE UNITED STATES OF AMERICA PRESENTLY DOES NOT HAVE AN ADEQUATE LEVEL OF PERSONAL DATA PROTECTION AS DETERMINED BY THE EUROPEAN COMMISSION'S ADEQUACY DECISION ON OCTOBER 6, 2015 (CASE C-362/14) AND ARTICULATED IN THE EUROPEAN UNION'S GENERAL DATA PROTECTION REGULATION AND HAS NOT RECEIVED A SIMILAR DESIGNATION OF ADEQUACY BY ANY OTHER FOREIGN DATA PROTECTION AUTHORITY. YOU AGREE TO THE TRANSFER OF YOUR DATA AND PERSONAL INFORMATION TO THE UNITED STATES OF AMERICA, HOWEVER, TO BE USED IN ACCORDANCE WITH THIS PRIVACY POLICY.

F. Obligations to Data Protection Authorities (DPAs)

We will respond diligently and appropriately to requests from DPAs about this policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of Personal Information, we will (1) cooperate with inquiries from the DPA responsible for the entity exporting the data and (2) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs' decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.

G. Contacting Our Data Protection Officer

To contact our designated Data Protection Officer, please send an email to: privacy@findyourfuture.net.

16. Changes to This Policy. We may change this Policy from time to time. If we make any changes to this Policy, we will change the "Effective Date" date set forth above. If we make any material change(s) to the Policy, we will post a notice on our Site prior to such changes(s) taking effect. Your continued use of the Site and/or any of our Services after the changes have been made will constitute your acceptance of the changes. Therefore, please read any such notice carefully. If you do not wish to continue using the Site or our Services under the new version of this Privacy Policy, please stop using the Site and our Services.

17. Contacting Us. If you have any questions about this Privacy Policy, please contact us at privacy@findyourfuture.net or write us at:

Find Your Future, Inc.

Attention: Legal Department

8 The Green Suite #11392

Dover, Delaware 19901