Last updated November 2024

Scooly Experts Privacy & Policy

Scooly Technology Inc. and its subsidiaries and affiliated companies, including but not limited to Scooly Education Technology Inc., EDX Partners Ltd., (collectively “Scooly”, “we”, “us”, and “our”) provide this Privacy Notice to inform you about our practices concerning the collection, use and disclosure of your Personal Information. This Privacy Notice applies to information we collect when you access and use our websites or when you otherwise interact with us through our websites or on other sites where we post this Privacy Notice. By using the websites located at www.myscooly.com, www.scooly.ca, www.scoolyapp.com, www.scooly.co, www.scooly.com (including all subdomains), or any other websites that we own or control which reference and link to this Privacy Notice (collectively, the “Sites”), and/or by using any portals, applications, interactive features, or the services provided by Scooly(collectively the “Services”), you agree to the information practices described in this Privacy Notice. If you do not agree to the terms of this Privacy Notice, you may not access or use the Sites or Services. This Privacy Notice is incorporated into our Terms of Use, and any other terms that post a link to this Privacy Notice and incorporate it by reference. References in this Privacy Notice to “Terms of Use” should be read as references to the Terms of Use applicable to the Site(s) or Service(s) that you are using. If you are working with an attorney, you may receive a separate agreement that governs your relationship; however, your use of the Site and/or our other Services will continue to be governed by the Terms of Use and this Privacy Notice where and as applicable.

SCOOLY TECHNOLOGY IS NOT A LAW FIRM AND, EXCEPT AS EXPRESSLY OTHERWISE STATED IN A BINDING AGREEMENT BETWEEN SCOOLY AND YOU, DOES NOT PROVIDE LEGAL ADVICE. YOUR USE OF THE SITE AND SERVICES, AND YOUR COMMUNICATION WITH SCOOLY, DOES NOT CREATE AN ATTORNEY-CLIENT RELATIONSHIP. EXCEPT AND UNLESS SCOOLY EXPRESSLY AGREES OTHERWISE, YOUR COMMUNICATIONS WITH SCOOLY ARE NOT PROTECTED BY THE ATTORNEY-CLIENT PRIVILEGE.

1. Information We Collect

When you use the Sites or Services, we collect certain Personal Information from you which can be used to contact or identify you, including, but not limited to, your name, gender, date of birth, telephone number, postal address, and email address (“Identity Information”). If you place an order for Services and/or pay a fee, we will collect additional payment and billing information from you, including, but not limited to, your credit/debit card information or bank account information (“Billing Information”). For the avoidance of doubt, we do not store or retain sensitive information such as full credit card or debit card numbers, bank account information, or other financial information that could be used directly to access a person’s financial account;; however, we do store the transaction tokens that can be used to retrieve, and in some cases submit, information associated with your transaction to our service providers (such as the last four digits of a payment card).

If you place an order for Services, you may also be required to provide information or documents necessary for preparation or filing of forms or applications to be submitted to government agencies, and if you file an application, we may receive from the government a unique receipt number assigned to your application (“Application Information”). Depending on the Services that you are seeking, Application Information may include certain sensitive personal information, including (without limitation) information about your age, race, disability, sexual orientation, religion, national origin, and/or racial or ethnic origin; your social security, driver’s license, state identification card, or passport number; your immigration status; birth certificate information; employment status and information about your employer. Together, your Identity Information, Billing Information, Application Information, and Usage Data (defined below) are referred to as “Personal Information.”

1.2. Usage Data

We also automatically collect certain Personal Information regarding your access to and use of the Sites and Services. This Personal Information includes your computer or device hardware and software, IP address, browser type, referring website URLs, domain names, access times, log files, pages on the Sites that you visit, and links you click on, and associated with information that directly relates to or could be used to identify you (“Usage Data”).

1.3. Cookies

Like many websites, we utilize devices to recognize you when you visit the Sites, track your interactions with the Sites, and personalize your experience. These include devices such as cookies, web beacons, pixels and similar devices. Cookies are small data files we transfer to your computer hard drive. We utilize some cookies that remain on your computer after you leave the Site so that we can recognize you when you return and provide a more personalized and helpful experience. We also utilize session cookies to enable certain features of the Sites, to better understand how you interact with the Sites and to monitor use of the Sites by Scooly users and web traffic routing on the Sites. Session cookies are deleted from your computer when you log off from the Sites and close your browser. You maintain control over some of the Personal Information we collect through the use of cookies, and you can set your preferences regarding the use of cookies through your browser settings. If you choose not to accept cookies, you may not be able to access portions of the Sites or all functionality of the Services.

1.4. EU Lawful Grounds

If you reside in the European Economic Area, Switzerland, or the UK (collectively the “EU”), and are subject to any one of (i) the General Data Protection Regulation, (ii) data protection laws implemented by member states of the EU in harmony with the General Data Protection Regulation, or (iii) the U.K. Data Protection Act of 2018, as amended and incorporated into U.K. law (collectively, the “GDPR”), you are a “ Data Subject” and we are a “Data Controller” for any Personal Information that constitutes “Personal Information” under the GDPR that is processed under this cyacy Notice. If you are not a Data Subject, the provisions in this section (and in Section 5) do not apply to you.

2. Use of Information We Collect

2.1. Account Creation

We use Personal Information you submit to us at the time of account registration, such as your name and email address, and any updated Personal Information you subsequently submit, such as a new email address, to create and maintain your account.

2.2. Operation of Our Business

We use your information, including Personal Information, primarily to operate our business and provide the Services to you, including the completion of immigration forms and/or fulfilling your requests for products and services (such as by emailing you regarding application updates).

2.3 Improvement of Our Business

We also use Personal Information to personalize the Services we provide to you. We may use your information to verify your identity, for fraud prevention, to enforce the applicable Terms of Use and to protect the integrity of the Site. We may also use your information to develop new features or Services and to improve the quality of our Services, to detect, investigate, and prevent malicious, deceptive, fraudulent, or illegal activities, or other activities that may violate our policies or be illegal, or otherwise to comply with our legal obligations.

2.4. Customer Service and Technical Support

We may use your information, including Personal Information, to respond to questions you have regarding use of our Services or to provide technical assistance.

2.5. Communications with You

We may contact you using the contact information you provide in order to respond to inquiries you send to us, to communicate with you regarding our Services and the services of our partners, and to market our Services, or those of our partners, to you, in accordance with applicable laws. We may send you emails advertising or promoting our Services or those of our partners. If you do not wish to receive such emails, you can choose to opt-out of receipt using the unsubscribe link within each email, or by sending an unsubscribe request to [email protected]

We also may use information about you, including Personal Information, to improve the effectiveness of our marketing and advertising efforts.

2.6. Internal Research

We may use information about you, including Personal Information, and other users, in aggregate form, for our own internal research and analytical purposes. For example, we may use certain types of your information to understand which features of our Services are being used most frequently.

Note that we use Personal Information to create de-identified, aggregated information regarding devices used to access our services, use of our Sites and related Services, and other similar information to provide us with a better understanding of our users. Statistical and aggregated information that we derive from Personal Information is excluded from the definition of “Personal Information” because it does not personally identify you.

2.7. Application Status

We may use your government receipt number from time to time to check your application status, so that we may provide you with pertinent general information about the steps in the application process.

3. Information Sharing and Disclosure

3.1. Your Privacy Rights

Scooly does not share your Personal Information with third parties for their marketing purposes without your consent. Scooly does not sell, rent, or lease its customer lists to third parties.

3.2. Upon Consent

We may share your information, including Personal Information, with third parties if you provide us with authorization to do so. For example, if you include Personal Information in a review or testimonial of our Services for posting to social media platforms, such information will be publicly disclosed upon posting.

3.3. Service Providers

We may share your Personal Information with third-party service providers, but only to the extent necessary for them to assist us in providing our Services. For example, if you purchase Services, we will share your Billing Information with third-party payment processors to the extent necessary to process your payment.

3.4. Responses to Legal Process, Subpoenas or Court Orders

We will not voluntarily disclose your Personal Information. However, we may disclose your Personal Information as required by law, such as in response to a court order, subpoena, or similar legal process legally requiring us to produce the information. If legally permitted and feasible, we will give you notice of our receipt of a demand for your Personal Information and provide you a reasonable time in which to seek to quash such demand in court, or otherwise obtain a withdrawal or modification of the demand, before complying with the demand.

3.5. Business Transfers

Your Personal Information may be included in the event that some or all of our assets are sold, assigned or transferred in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. As a general matter, however, an acquiring party cannot retroactively change the Privacy Notice that was in place when Scooly collected your Personal Information.

3.6. Academic Research

We may share non-personally identifiable and non-privileged information based on Personal Information provided by you and other users, in aggregate form, to third-party academic researchers. We require all third-party researchers to use such information for no purposes other than academic research. For example, we may use certain types of non-personally identifiable and non-privileged information to help researchers study factors that reducebarriers facing applicants navigating the immigration system.

3.7 Third Party Cookies

We use Google AdWords Conversion tracker and other Google services (collectively “Google Cookies”) that place cookies on a browser. These cookies help us increase our Sites’ effectiveness for our visitors. These cookies are set and read by Google. To learn more about Google Cookies and how to opt out, please visithttps://policies.google.com/technologies/ads.

We also use AdWords remarketing to market our Sites across the web. It places cookies on a browser that are then read by Google or other third parties, such as advertising networks, which may then serve you an ad on a third party website. You may opt out of this type of ad serving using thelink to Google.You can also visit the Network Advertising Initiative opt-out page at https://www.networkadvertising.org/choices/.

4. Policy Regarding Children

Our Sites and Services are not intended for persons under 18 years of age, and we do not knowingly process Personal Information from persons under 18 years of age, except to the extent necessary to provide our Services to the parent or guardian of such persons. If you are a parent or guardian and believe that your child has provided us with Personal Information directly without your consent, please contact us at [email protected]. If we are informed that a person under 18 years of age has provided us with Personal Information for any reason other than to enable us to provide the Services, we will delete such Personal Information from our files.

5. EU Data Transfer and Individual Rights

5.1. Data Transfer Notice

We are located in the United States and transfer your Personal Information for processing by our affiliates in the Philippines, as well as our service providers in jurisdictions outside of the U.S. and the EU. We make such transfers to the Philippines and other non-U.S. jurisdictions in the absence of an adequacy decision because it is necessary for the performance of a contract with you, or with your explicit consent. We may transfer your Personal Information to a processor located outside of the EU to assist us in providing our Services in accordance with applicable laws.

5.2. Individual Rights

If you are a Data Subject located in the EU, you may exercise certain rights under the GDPR, which are described below. If you have an account for our Services, you may use your account to access, correct, or change Personal Information that you have provided to us. If you do not have an account, you may email us at [email protected] to access, correct, or change your Personal Information, or to request access to (or information about our processing of), transfer of, and rectification or erasure of your Personal Information or restriction of processing; and to object to processing. In the email, specify the nature of your request and the information that is the subject of your request. Note that you must provide specific and detailed information about your request necessary for us to respond to and carry out your request.

We will endeavor to respond to your request within the timeframe required by law. In the event that responding to your request will require a longer period than the standard frame frame required by law, we will inform you within that timeframe if an extension is necessary and the reason for the delay.

If we are processing your Personal Information based upon the lawful ground of your consent, you have the right to withdraw your consent for such processing at any time without affecting the lawfulness of the processing based on consent before it is withdrawn. To withdraw consent, email us at [email protected]

In addition to the rights granted by applicable laws, you may submit a complaint about our processing of your Personal Information to your national data protection regulator.

6. Security

We have put in place physical, electronic and managerial procedures to protect the security of the Personal Information we collect, both during transmission and once received. This includes, but is not limited to, encryption, access control and audit logging of Personal Information (as necessary and applicable). However, no method of transmission over the internet or method of storage is 100% secure. We cannot guarantee that our security measures will prevent our computer systems from being accessed illegally, nor can we guarantee that the information on our computer systems will not be viewed or stolen. Accordingly, except and unless expressly otherwise set forth in a binding agreement between Scooly and you, Scooly disclaims all liability for the theft of, interception of, or loss of, or unauthorized access or damage to, your information. You acknowledge that use of the Sites and Services is at your own risk.

7. Google Analytics

We use Google Analytics to collect information about use of the Sites. We use the information we get from Google Analytics to improve the Sites and Services. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Sites by disabling cookies on your browser.

8. Changes to Privacy Notice

Scooly may make changes to this Privacy Notice at any time. If we make any material changes we will post the revised Privacy Notice on the Sites prior to or upon any changes becoming effective. You should review our Privacy Notice each time you access the Sites or use the Services. Your continued use of the Sites or Services following the posting of any changes or notice to you of the changes constitutes your agreement to such changes.

9. Retention of Personal Information

At a minimum, we will retain your Personal Information for as long as it may be needed to provide you Service and as needed to comply with our legal obligations or for our legitimate business purposes. Unless you request deletion of your Personal Information sooner, we may hold any of your Personal Information for the maximum period permitted by applicable law . Upon request, Scooly will inform you about whether we hold any of your Personal Information. You may terminate your account and request deletion of your Personal Information by contacting us at [email protected]. In some situations, we may be legally required to retain your Personal Information or for other reasons will not be able to comply with a request to delete data.

We’ll retain your information as long as it’s necessary to serve you or comply with legal obligations and may hold it for the maximum period permitted by applicable law. You may request that we delete your Personal Information at any time.

10. Disclosures Under State Privacy Laws

10.1 Categories of Personal Information

In addition to the rights described in this Privacy Notice, the California Consumer Privacy Act of 2018 (“CCPA”), as well as privacy laws in Colorado (collectively, “State Privacy Laws”), provide consumers residing in that state certain additional rights with respect to their Personal Information. If you are a resident of one of the states named above, you may have additional rights with respect to your Personal Information. This section also applies to residents of the above states who are interacting with Scooly in a business or commercial capacity.

In the preceding twelve months, we have collected and used the following categories of Personal Information as described below:

Category of Personal Information	Examples	Shared With (Service Provider, Government Entities, Business Partners, or Other)	Processing Purpose
A. Identifiers.	A real name, alias, Internet Protocol address, email address, account name, or other similar identifiers.	Service providers, advertising and marketing partners, and government entities.	Internal processing purposes and advertising/marketing purposes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A real name, postal address, or telephone number. Some personal information included in this category may overlap with other categories.	Service providers and government entities.	Internal processing purposes
C. Characteristics of protected classifications under California or federal law	Age, race, disability, sexual orientation, religion, national origin.	Service providers and government entities.	Internal processing purposes
D. Commercial information.	Records of products or services that you have purchased, considered, or otherwise used on our Site.	Service providers.	Internal processing purposes and advertising/marketing purposes
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Service providers and advertising and marketing partners.	Internal processing purposes and advertising/marketing purposes
G. Geolocation data.	Approximate physical location or movements based on Internet information.	Service providers.	Internal processing purposes and advertising/marketing purposes
I. Professional and/or employment data.	Employer, job title, affiliated organization, and area of responsibility and industry.	Service providers and government entities.	Internal processing purposes and advertising/marketing purposes
J. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).	Educational transcripts; diplomas.	Service providers and government entities.	Internal processing purposes and advertising/marketing purposes
L. Sensitive personal information	A social security, driver’s license, state identification card, or passport number; racial or ethnic origin; religious or philosophical beliefs; immigration status; birth certificate information.	Service providers and government entities.	Internal processing purposes

We do not use or disclose Personal Information in categories (C) or (L) for any purpose except to provide you with the services that you have requested. We retain Personal Information for as long as necessary to carry out the purposes for which we originally collected it and for other purposes described in this Privacy Notice.

10.2 Notice of Information Collected and/or Disclosed for “Sales” or “Sharing”

California law and other State Privacy Laws require that we notify you about Personal Information that we “sell” or “share.” Under the CCPA, “sale” means the disclosure of Personal Information to third parties in exchange for valuable consideration, while “sharing” means the disclosure of personal information to a third party for cross-context behavioral advertising. For purposes of the CCPA, we do not knowingly sell or share Personal Information under the age of 16. In the twelve months preceding the date on which this Privacy Notice was last revised, we have “sold” or “shared” Personal Information for cross-context behavioral advertising purposes with the following third parties:

Category of Personal Information	Examples	Shared With (Service Provider, Government Entities, Business Partners, or Other)
A. Identifiers.	A real name, alias, Internet Protocol address, email address, account name, or other similar identifiers.	Service providers, advertising and marketing partners, and government entities.
D. Commercial information.	Records of products or services that you have purchased, considered, or otherwise used on our Site.	Service providers.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Service providers and advertising and marketing partners.

The above Personal Information is used to display advertisements to you based on Personal Information obtained from your activities over time and across nonaffiliated websites or online applications.

You may submit your request to opt out of the sale of your Personal Information under the CCPA by contacting us at [email protected].

10.3 Consumer Rights under State Privacy Laws

Subject to certain limitations, under State Privacy Laws, residents of the affected states have the right to (1) request to know more about the categories and specific pieces of Personal Information we collect, use, and disclose, (2) request deletion of your Personal Information, and/or (3) request correction of your Personal Information. You may make these requests by emailing [email protected]. We will not discriminate against you if you exercise your rights under applicable State Privacy Laws.

Under the CCPA, consumers have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the categories of Personal Information that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

If we deny your request, you may appeal our decision by contacting us using the contact methods provided above. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

You may only make a verifiable consumer request twice within a twelve-month period under the CCPA. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative of that person.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

The rights above may be limited in some circumstances—for example, if fulfilling your request would reveal Personal Information about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in maintaining.

10.4 Opt-Out Preference Signals

Some browsers allow you to enable privacy controls in the browser’s settings to automatically signal your opt-out preference to the websites you visit (e.g., Global Privacy Control). As of the date on which this Privacy Policy was last updated, however, there is no standardized DNT signal, and so no uniform technological standards for recognizing and implementing such signals. As such, our Services do not currently respond to browser DNT signals or similar signals. If you do not wish to be tracked, you may also be able to opt out by selecting certain options in the settings browser or device that you use to access the Services, or by using certain third-party applications and programs.

10.5 California Notice of Financial Incentive

The CCPA also requires that we notify you if we provide you a program, benefit, or other offering, related to the collection, deletion, or sale of Personal Information, which it defines as a “financial incentive.” Sometimes, consumers sign up or provide us with their Personal Information (such as their email address) to participate in promotions. As such, under the CCPA, our promotions may be considered financial incentives provided in exchange for the collection and retention of Personal Information.

We offer these promotions to enhance our relationship with you or so you can engage with us while receiving some of these benefits. There is no obligation to opt-in and consumers may opt-out at any time. The details of each program are contained in each such program offering.

The consumer data received in exchange for your participation is dependent on a number of factors, including, for example, whether and to what extent you take advantage of any offerings and whether and to what extent you opt out of any offerings but is roughly equivalent to the value of the product incentive or promotion offered.

11. Questions

If you have any questions regarding this Privacy Notice, please contact us at [email protected].

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