Effective Date: 12/2024

Last Updated: 01/2026

 

1. INTRODUCTION

 

This Privacy Policy ("Policy") governs the collection, use, and disclosure of Personal Information by AchieveIT Pathways Program ("Company," "we," "us," or "our") in connection with our website located at https://www.achieveitpathwaysprogram.com (the "Site") and our educational coaching and pathway planning services (the "Services"). This Policy is a legally binding document between you ("User," "you," or "your") and the Company.

 

By accessing the Site or using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. If you do not agree with any provision herein, you must immediately cease all use of the Site and Services.

 

2. DEFINITIONS

 

“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including but not limited to identifiers, commercial information, internet activity, geolocation data, professional or employment-related information, and inferences drawn from such data.

"Sensitive Personal Information"  includes precise geolocation, racial or ethnic origin, religious beliefs, health data, and information concerning a minor student.

"Service Providers" are third-party entities that process Personal Information on our behalf pursuant to written contracts with specific data protection obligations.

 

3. INFORMATION COLLECTION PRACTICES

 

3.1 Information You Provide Directly:

We collect Personal Information you voluntarily provide, including:

Identifiers: Full name, email address, telephone number, postal address, parent/guardian information.

Commercial Information: Service enrollment details, payment history, billing information.

Education Information: Student academic records, standardized test scores, grade point average, school transcripts (provided by you), extracurricular activities, academic goals, and target institutions.

Protected Classification Characteristics: Age, which may be collected to provide age-appropriate Services.

Correspondence: Communications via email, contact forms, or messaging platforms.

 

3.2 Information Collected Automatically:

Technical Data: Internet Protocol (IP) address, browser type and version, device identifiers, operating system, and system configuration.

Usage Data: Pages visited, time and duration of visits, clickstream data, referring/exit pages, and other diagnostic data.

Tracking Technologies: We utilize cookies, web beacons, and similar technologies. Our Cookie Policy explains how we use cookies and similar tracking technologies on our website, https://www.achieveitpathwaysprogram.com. By using our site, you consent to the use of cookies as described below.

 

What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help the site function properly, remember your preferences, and understand how visitors use the site.

 

How We Use Cookies

We use cookies for essential, functional, and analytical purposes:

- Essential Cookies: Required for the website to operate (e.g., security, session management). You cannot opt out of these.

- Analytical Cookies: Help us understand how visitors interact with our site (e.g., page views, traffic sources). This data is anonymous.

- Functional Cookies: Remember your preferences (e.g., language, cookie consent choices) to improve your experience.

 

We do not use advertising or third-party marketing cookies on our site.

 

Managing Your Preferences

When you first visit our site, you can accept or decline non-essential cookies via our cookie banner. 

 

Additionally, you can manage or disable cookies through your web browser settings. Please note that disabling certain cookies may affect the functionality of our site.

 

Changes to This Policy

We may update this Cookie Policy occasionally. The "Last Updated" date at the top will reflect any changes.

 

3.3 Information from Third Parties:

We may receive information from schools (with authorization), payment processors, or publicly available sources to supplement our records, always in compliance with applicable law.

 

4. LEGAL BASIS AND PURPOSES OF PROCESSING

 

We process your Personal Information based on the following legal grounds and for the specified purposes:

 

Legal Basis |Purpose of Processing|

 

Performance of a Contract 

To execute and administer your enrollment agreement; to provide the contracted Services, including personalized coaching sessions, material preparation, and progress tracking.

Legitimate Interests

To operate and secure the Site; to analyze and improve Service delivery; for internal administrative purposes; to prevent fraud or misuse. 

Consent

For direct marketing communications (where required by law); for the collection of Sensitive Personal Information or student data where not otherwise permitted. 

Legal Obligation 

To comply with record-keeping, tax, and other regulatory requirements. 

 

5. INFORMATION SHARING AND DISCLOSURE

 

We do not sell, rent, or trade your Personal Information to third parties for their marketing purposes.

 

We may disclose Personal Information to the following categories of recipients:

Service Providers: Strictly under contract for purposes such as payment processing (e.g., Stripe, PayPal), email delivery (e.g., Mailchimp), video conferencing (e.g., Zoom), and customer relationship management vendors such as Lumion and Flexxbuy.

Professional Advisors: To our lawyers, auditors, and insurers as necessary.

Legal and Regulatory Authorities: In response to valid legal process (subpoena, court order, search warrant), to defend our legal rights, or to protect the safety of persons.

Business Transferees:In connection with a merger, acquisition, financing, or sale of assets, subject to the acquirer's agreement to adhere to this Policy.

 

6. DATA RETENTION

 

We retain Personal Information only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (e.g., tax, accounting, legal obligations). Our standard retention period for client records post-service termination is 8 years. Anonymized data may be retained indefinitely for analytics.

 

7. DATA SUBJECT RIGHTS

 

Depending on your jurisdiction (e.g., California, EU, UK, Canada), you may have certain rights regarding your Personal Information, which may include:

*   The right to access and receive a copy of your data.

*   The right to correct inaccuracies.

*   The right to request deletion.

*   The right to data portability.

*   The right to restrict or object to certain processing.

*   The right to withdraw consent (without affecting the lawfulness of prior processing).

*   The right to opt-out of the "sale" or "sharing" of Personal Information (as defined under laws like the CCPA).

 

To exercise any of these rights, please submit a verifiable request to us via the contact details in Section 12. We will respond in accordance with applicable law and may need to verify your identity before processing your request.

 

8. CHILDREN'S PRIVACY (COPPA & FERPA COMPLIANCE)

 

Services that are directed at minors under the age of 18. In compliance with the Children's Online Privacy Protection Act ("COPPA"), we require verifiable parental consent before collecting, using, or disclosing Personal Information from children under the age of 13. Parents/guardians may review their child's information, request deletion, and refuse further collection.

 

We treat all student educational records provided to us as confidential and handle them in a manner consistent with the spirit of the Family Educational Rights and Privacy Act ("FERPA"), even if we are not directly subject to it as a private entity.

 

9. INTERNATIONAL DATA TRANSFERS

 

We operate from within the United States. If you are located outside the U.S., please be aware that your information will be transferred to, processed, and stored in the U.S., where data protection laws may differ. By using our Services, you consent to this transfer. Where required, we implement appropriate safeguards such as Standard Contractual Clauses for transfers out of the European Economic Area or UK.

 

10. SECURITY MEASURES

 

We implement and maintain commercially reasonable administrative, technical, and physical security measures designed to protect your Personal Information from unauthorized access, destruction, use, modification, or disclosure. These include encryption, access controls, and secure network architectures. However, no security system is impenetrable, and we cannot guarantee absolute security.

 

11. POLICY UPDATES

 

We reserve the right to amend this Policy at our sole discretion. Material changes will be communicated by posting the updated Policy on the Site with a revised "Last Updated" date. Your continued use of the Site or Services following such posting constitutes your binding acceptance of the changes.

 

12. CONTACT INFORMATION

 

For questions, to exercise your rights, or to lodge a complaint regarding this Policy or our data practices, contact:

 

AchieveIT Pathways Program

info@achieveitpathwaysprogram.com

Phone:301-542-6660