Last Updated: March 2025
Shorelight, LLC and its affiliates (“Shorelight”, “we” or “us”) are committed to protecting your privacy. We have prepared this Privacy & Cookie Notice (“Notice”) to describe our practices regarding the Personal Information that may be collected by Shorelight in relation to our research, admissions, enrollment, on-campus support, academic, career, and other services we offer (the “Services”), how we may use the information, with whom we may share it, and the rights and choices available to you regarding our use of the information, including rights and choices available under U.S. laws, such as the California Consumer Privacy Act, and international laws, such as the European Economic Area General Data Protection Regulation and the People’s Republic of China Personal Information Protection Law (“Privacy Laws”). We also tell you how to contact us about our privacy practices. “Personal Information” is any information about an identified or identifiable person. By using our Services, you acknowledge that we will process your Personal Information in accordance with this Notice.
Please read this Notice carefully to understand our Personal Information handling practices. If you do not agree with the data practices described in this Notice, we advise you not to use our website or Services. BY CONTINUING TO USE OUR SERVICES AND/OR SUBMITTING YOUR PERSONAL INFORMATION, YOU CERTIFY THAT YOU MEET THE AGE AND OTHER ELIGIBILITY REQUIREMENTS FOR THE SERVICE AS SET FORTH IN THIS NOTICE AS WELL AS THE TERMS AND CONDITIONS.
In some cases, we receive Personal Information pertaining to students from educational institutions, such as information about class rosters and data from students who use our learning platforms at the direction of an educational agency or institution (“School Data”). School Data is only used by us to support our customer institutions and provide the Services requested by the institution’s administrators and course instructors. We handle School Data on behalf of our customer institutions, who determine the purposes and means of handling School Data, subject to applicable privacy and data protection laws, including, but not limited to, the U.S. Family and Educational Rights Privacy Act (FERPA). In such cases, the processing of your Personal Information will be subject to their privacy policies and Personal Information handling practices. The processing of the Personal Information constituting School Data is not addressed in this Notice. IF YOU WISH TO OBTAIN INFORMATION OR EXERCISE ANY OF YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION THAT CONSTITUTES SCHOOL DATA, PLEASE READ THE PRIVACY POLICIES AND OTHER NOTICES OF THE RELEVANT EDUCATIONAL INSTITUTION CAREFULLY AND/OR CONTACT THE INSTITUTION DIRECTLY. ALTHOUGH WE MAY PLACE CONTEXTUAL ADVERTISING ON PAGES USED BY STUDENTS, WE DO NOT USE ANY PERSONAL INFORMATION IN SCHOOL DATA FOR TARGETED ADVERTISING.
1. Information We Collect (Notice at Collection)
If you are a student, a counselor, a representative of an institution, a current or prospective Shorelight employee, or a commercial customer, supplier, or partner, in many cases, we collect Personal Information directly from you and your device(s) or third parties. For students, these third parties often include individuals and organizations who provide recruitment services to us (“Agents”) and schools to which we provide our Services (“Customer Educational Institutions”). The Personal Information we collect, use and disclose about you will vary depending on how you interact with us and our Services.
We store all Personal Information for as long as necessary to fulfill the purposes set out in this Notice, or for as long as we are required to do so for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal or regulatory obligations, or where we otherwise reasonably believe that we have a legitimate and lawful reason to retain Personal Information. We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when your Personal Information is no longer necessary for the purposes for which we process it unless we are required by law to keep your Personal Information for a longer period. When determining the specific retention period, we consider various criteria, such as the type of service provided to you, the nature and length of our relationship with you, mandatory retention periods provided by law, and relevant statutes of limitations.
When you interact with our Services, we may collect, use and disclose your Personal Information in the following ways:
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Category and Sources of PI
Account and Contact Information
When you create an account to access our Services, we may collect Personal Information such as:
- Identifiers, such as real name, email address, country of residence, and phone number
- Education information, such as the name of the educational institution you attend, degree type, and start date of your degree
- Citizenship or immigration status
- Any other sensitive Personal Information you share when you create an account on our Services or otherwise access our Services
Purposes for Collecting this PI
We use this type of information to identify you and communicate with you, including:
- To provide the Service.
- To send transactional messages.
- To send marketing communications, surveys and invitations.
- To personalize our communications and provide customer service.
Disclosures of this PI
We may disclose this type of information to service providers and contractors who help us fulfill these purposes.
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Category and Sources of PI
Enrollment Information
When you use our Services to apply to attend one or more of our Customer Educational Institutions, we may collect Personal Information such as:
- Any Personal Information that is requested on the school application(s) you choose to complete, which varies depending upon the school
- Any Personal Information you choose to include in your personal essay
- Education information, such as your student identification number and enrollment status
We collect this type of information from you and from our Customer Educational Institutions.
Purposes for Collecting this PI
We use this type of information:
- To facilitate the processing of your enrollment application on behalf of our Customer Educational Institutions.
- To evaluate your academic qualifications and inform you of academic programs you may be interested in pursuing.
- To help our Customer Educational Institutions understand if and how we assisted you in relation to your enrollment in their programs and to abide by contractual obligations related to our Services we provide to our Customer Educational Institutions.
- To otherwise support the Services we provide to our Customer Educational Institutions.
Disclosures of this PI
We may disclose this type of information to service providers and contractors who help us fulfill these purposes.
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Category and Sources of PI
Government Issued Identifiers
When we are required to make payments to you, we may collect Personal Information such as:
- Social Security number
- Tax ID number
Purposes for Collecting this PI
We use this type of information for identity verification and legal compliance, such as reporting payments made to contractors, suppliers, and/or others as required by law.
Disclosures of this PI
We may disclose this type of information to service providers and contractors who help us fulfill these purposes.
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Category and Sources of PI
Account Log-In Information
When you establish an account or change your password, we may collect Personal Information such as:
- Usernames and/or passwords
- Account recovery information (such as security questions and answers)
Your account log-in in combination with any required security or access code, password, or credentials allowing access to your account may be considered sensitive Personal Information (as defined in Privacy Laws).
Purposes for Collecting this PI
We use this type of information:
- To identify and authenticate you.
- To enable you to engage in transactions with us (such as interacting with us online).
- To help ensure security and integrity.
- To debug to identify and repair errors that impair existing intended functionality.
- To maintain or service your account.
- To provide customer service.
- For similar business purposes.
Disclosures of this PI
We may disclose this type of information to service providers and contractors that assist with our information technology and security programs.
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Category and Sources of PI
Relationship Information
When we believe you may be interested in our Services, we may collect Personal Information such as:
- Personal characteristics, some of which may be characteristics of protected classifications under California or federal law, like your age or gender
- Social media profile details
- Marketing and communication preferences
- School affiliation
- Professional credentials (degree information, academics interests)
- Publicly available sources, such as social media sites or educational institution websites
- Data brokers and agents that enhance our records to help us understand our customers
Purposes for Collecting this PI
We use this type of information:
- To better understand you and to understand our customers generally.
- To design products, Services and programs that delight our customers, including promotions and loyalty programs.
- For personalization, including to send you personalized offers and invitations and complimentary products (such as teacher guides)
- To enable you to participate in discussion groups and forums.
- To identify prospective customers.
- For internal business purposes, such as quality control, training and analytics.
Disclosures of this PI
We may disclose this type of information to service providers and contractors, including those that support our marketing programs.
As permitted by law, we may share this information with joint marketing partners and companies with whom we have similar arrangements.
You can opt-out of the sharing of your information with joint marketing partners and similar third parties by sending an email to privacy@shorelight.com
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Category and Sources of PI
Transaction and Interaction Information
When you transact with us or interact with us online, we may collect Personal Information such as:
- Records related to your response to promotions, including sweepstakes entries and complimentary products
- Commercial information, including records of products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
- Records related to downloads and purchases of online content, including records of use or sharing of our content
- Customer service records
- Visitor logs
Purposes for Collecting this PI
We use this type of information:
- To fulfill our business relationship with you and your company (if applicable) and for customer service purposes.
- To administer programs, including promotions, sweepstakes and influencer programs.
- For recordkeeping and compliance.
- For internal business purposes, such as finance, quality control, training, reporting and analytics and dispute resolution.
- For risk management, fraud prevention and similar purposes.
Disclosures of this PI
We may disclose this type of information to service providers and contractors as needed to complete the transaction, including delivery companies.
If you are interacting with us on behalf of an educational institution, we may disclose the information to that institution. Please see Business Customer Data below.
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Category and Sources of PI
Online & Technical Information
When you visit or interact with our online platforms, websites, or applications we may collect Personal Information such as:
- Customer number (assigned by us when you create an account)
- Internet Protocol address
- Device identifiers and system identifiers
- Device characteristics
- Advertising ID
- Server and application logs
- Data from cookies, pixel tags and other online tools
Purposes for Collecting this PI
We use this type of information:
- To identify you or your device, including to associate you with different devices that you may use.
- For system administration, technology management, including optimizing our websites and applications.
- For information security and cybersecurity purposes, including detecting threats.
- For recordkeeping and reporting, including for data matching and maintaining logs and records as part of Transaction and Interaction Information.
- To better understand our customers and prospective customers and to enhance our Relationship Information, including by associating you with different devices and browsers.
- For online metrics and analytics, ad delivery, and targeted advertising purposes.
Disclosures of this PI
We may disclose this type of information to our service providers and contractors who fulfill orders, support our information technology and security programs (including companies that assist with fraud prevention, detection, and mitigation), or host our websites and to:
- Third-party network advertising and analytics partners
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Category and Sources of PI
Audio and Visual Information
When you contact our call center or visit our facilities, we may collect Personal Information such as:
- Photographs and videos
- CCTV recordings
- Call center recordings and call monitoring records
- Voicemails
Purposes for Collecting this PI
We use this type of information:
- To respond to your communications and assist you in the manner requested.
- For internal business purposes, such as call recordings used for training, coaching or quality control.
- For premises security purposes and loss prevention.
Disclosures of this PI
We may disclose this type of information to our service providers and contractors that support our information technology and security programs, and our loss prevention programs.
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Category and Sources of PI
Financial Account Information
When you purchase our Services, we may collect Personal Information such as:
- Payment card information, including debit card or credit card number in combination with any required security or access code, which may be considered sensitive Personal Information (as defined in Privacy Laws)
- Financial account information, including account number and routing number
Purposes for Collecting this PI
We use this type of information as needed to complete transactions with you, such as processing payments and issuing refunds.
Disclosures of this PI
We may disclose this type of information to our service providers and contractors, such as our payment processors, financial institutions and others as needed to complete the transactions and for authentication, security, and fraud prevention.
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Category and Sources of PI
Health Information Shorelight does not generally collect information concerning your health.
In some cases, individuals may provide information concerning health to us, such as if needed to accommodate a disability or in connection with workplace accidents and occupational safety.
We collect this information directly from you or other individuals, such as in the event of an accident or incident in one of our offices.
Purposes for Collecting this PI
We use this type of information for the specific purpose for which it was collected, such as to accommodate disabilities and enable accessibility of our products, Services and facilities, or for occupational health and safety programs.
Disclosures of this PI
We may disclose this type of information to service providers, contractors or others as needed for the specific purpose for which it was collected, such as to first responders, healthcare providers, our insurers, or occupational health and safety authorities.
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Category and Sources of PI
Business Customer Data
When you transact with us on a commercial level (i.e., when you or the organization you work for engages in a business-to-business or “B2B” transaction with us), or when we believe you may be interested in transacting with us on a commercial level, we may collect Personal Information such as:
- Information about your professional role within the organization you work for, your authorization to use products and Services, and your authority to agree to legal terms
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
- Information about customer service and training we provide to you
- Your signature
Purposes for Collecting this PI
We use this type of information:
- To fulfill our business relationship with you and/or your organization.
- To develop and maintain our relationship with you and with your organization.
- For recordkeeping and compliance, including dispute resolution.
- For internal business purposes, such as finance, quality control, training, reporting and analytics.
- For risk management, fraud prevention and similar purpose.
Disclosures of this PI
We may disclose this type of information to our service providers and contractors and to your organization and third parties that your organization affiliates or transacts with, as needed to facilitate our commercial relationship (such as including your Personal Information on purchase documents that you authorize).
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Category and Sources of PI
Compliance Data
When you interact with us in any manner, we may collect Personal Information such as:
- Records that demonstrate compliance with applicable laws, such as tax laws, occupational safety laws or privacy laws.
- Records necessary for financial reconciliation.
- Records pertaining to academic and/or professional misconduct.
- Records relating to complaints and internal investigations.
Purposes for Collecting this PI
We use this type of information:
- To comply with and demonstrate compliance with applicable laws.
- To respond to lawful requests or facilitate legal processes, including use in litigation and regulatory matters, use in connection with civil, criminal, administrative, or arbitral proceedings, use before regulatory or self-regulatory bodies, for service of process, for investigations in anticipation of litigation, or for execution or enforcement of judgments and orders.
- To protect or defend the rights, safety, or property of us, users of the Services, or any person, including to enforce our agreements, policies, and terms of use.
- For internal business purposes, such as risk management, audit, internal investigations, reporting, analytics.
Disclosures of this PI
We may disclose this type of information to our service providers and contractors, including our lawyers, auditors and consultants as well as other individuals or entities (such as government agencies or offices, courts, opposing law firms, process servers, and parties to litigation) in connection with legal matters as required or permitted by law.
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Category and Sources of PI
Employee and Employment Application Data
If you apply for a job with us or are employed by us, we may collect Personal Information such as:
- Identifiers, such as real name, address, email address, phone number, driver’s license or state identification card, or passport number
- Employment history
- Educational history
- Criminal history
- Health insurance and other benefits-related information
- Characteristics of protected classifications under California or federal law, such as age, racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership
- Contents of mail, email, and text messages sent using our systems or devices
- Precise geolocation
- Other professional or employment-related information
Purposes for Collecting this PI
We use this type of information:
- To evaluate your employment application and performance.
- To evaluate and respond to your requests for accommodations.
- To perform other human resources management processes.
Disclosures of this PI
We may disclose this type of information to our service providers and contractors that support our human resources management processes.
We may also disclose Government Issued Identifiers, Financial Account Information, and Health Information, and Compliance Data as described above.
Disclosures to Affiliates and business transferees. In addition to the disclosures described in the table above, any Personal Information we collect may be disclosed to our parent company, subsidiaries, joint ventures, and other companies under a common control (collectively, “Affiliates”) to use consistent with this Notice, and to third parties in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to such third parties.
Disclosures with your consent. We may share Personal Information about you with others for their own uses whenever you consent to or direct such sharing. Please note that we may also use and disclose information about you that is not personally identifiable. For example, we may publish reports or create products that contain de-identified, aggregated or statistical data, or share such data with third parties in a manner that does not identify particular users. These reports and products do not contain any information that would enable the recipient to contact, locate or identify you.
Cookies. We use Cookies and other technological tools to automatically collect information about your computer and your use of our Services. Please read our “Cookie Notice” for more information on how we use Cookies and other Tracking Technologies.
2. Your Rights and Choices Regarding Your Personal Information
We offer you choices regarding the collection, use, and sharing of your Personal Information. When you receive promotional email communications from us, you may “opt out” by following the unsubscribe instructions provided in emails you receive from us. To revoke permissions that you may have given to send text messages, text STOP in response to any message. Please be aware that if you unsubscribe from emails or opt out of texts using these methods, we will process your opt-out request only for the specific email address or telephone number from which you send your opt-out communication. So, for example, if you have more than one email address or if you have changed your email address, your opt-out request may not be processed for any email that you have not identified in your opt-out request.
You can also CLICK HERE for help opting out of receiving all marketing communications from us. Please include your name, address and the email address(es) and/or phone number(s) that you want to opt out.
If you believe you have opted out, but continue to receive emails from us, please contact us as set out under the “Contact Information” <INSERT LINK TO SECTION 8: CONTACT INFORMATION> section in this Notice, and we will endeavor to resolve the issue.
Please note that even if you opt out of promotional emails, we may still need to contact you with important information about your account. For example, even if you opt out of promotional emails, we may still send you account activity confirmations for security purposes.
Most web browsers are set to accept Cookies by default. If you prefer, you can typically remove and reject Cookies from our Services, as described in our Cookie Notice. If you remove or reject our Cookies, it may affect how our Services work for you.
Please note that you may have additional privacy rights under the laws of your jurisdiction, as described in our Additional State/Country-Specific Notices linked below, which supplement this Notice.
3. Security of Your Personal Information
No system is 100% secure, and therefore we can’t provide assurance with 100% certainty that your Personal Information will be secure. If you have any questions about security of our Services, you can contact us as set out in the “Contact Information” section below.
You can help us protect your Personal Information by:
Choosing strong passwords and keeping them confidential.
Being careful about what Personal Information you share online.
Reporting any suspicious activity to us immediately via our link.
4. Changes to this Privacy Notice
From time to time, we may update this Notice to reflect new or different privacy practices. You can determine when this Notice was last updated by referring to the “Last Updated” date referenced at the top of this Notice. Changes to this Notice will become effective upon posting of the updated Notice. We encourage you to periodically check this Notice for updates. Your continued use of the Services subsequent to any such change to this Notice constitutes your acceptance of the change.
5. Children
We do not knowingly or intentionally collect information about children under 16. If you believe that we have unknowingly collected any Personal Information from a child, please contact us as set out in the “Contact Information” section below.
6. Links to Third Party Websites
We may provide links to websites and services provided by third parties. We have no control over these websites, and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Services, and we encourage you to learn about third parties’ privacy and security policies before providing them with your Personal Information.
By using the Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third-party websites.
7. International Data Transfers
Shorelight is based in the United States. If you provide us with your Personal Information when using the Services from China, the EEA, the UK, or other regions of the world with laws governing data collection and use that may differ from US law, then please note that you are transferring your Personal Information outside of those regions to any country where we have facilities or in which we engage service providers, in particular the United States. The United States and these other jurisdictions may not provide equivalent levels of data protection as your home jurisdiction.
8. Contact Information
We welcome your comments or questions regarding this Notice. Please e-mail us at privacy@shorelight.com or contact us at the following address:
Shorelight, LLC
2 Seaport Ln., Suite 500
Boston, MA 02110
Attn: Legal Department