The Princeton Review and Tutor.com Privacy Policy
Effective Date: February 22, 2023
Tutor.com, Inc. and its subsidiaries, including TPR Education, LLC d/b/a The Princeton Review (collectively, “we,” “us,” or “our”) take your privacy seriously and understand the importance of protecting your personal information. Therefore, this Privacy Policy provides information about our privacy practices.“Personal information” means, unless otherwise defined by applicable law, any information about, that identifies, that relates to, that is linked to or associated with, or that is reasonably linkable to or reasonably capable of being associated with an identified or identifiable individual. For clarity, this Privacy Policy does not apply to our employees, job applicants, and independent contractors.
By visiting the websites located at www.princetonreview.com and at www.tutor.com and other websites and mobile applications which link to this Privacy Policy (collectively, “Sites”) or using the products or services offered through this Site, you agree to this Privacy Policy, as it may be amended from time to time. This Privacy Policy is incorporated into the Terms of Use for this Site.
For Parents of Children under the Age of 13
For any user under the age of 13, we must have permission from such user’s parent or legal guardian (obtained by the user’s school or provided by the user’s school on behalf of the user’s parent or legal guardian if the user is using our program through the user’s school or obtained by us) before we collect any personal information of such user on the Site or use or disclose such personal information. You are welcome to contact us at 800-2REVIEW or prep@review.com to review any personal information we have collected about your child. You may request that we delete this information or specify that we collect no more of your child’s information. We will need to verify the identity of anyone requesting information about a child under the age of 13 to ensure that the person is in fact the child’s parent or legal guardian. We do not correspond with users under the age of 13 about products, services, and events of other organizations.
Information We Collect
We collect information through the sources described below.
Information You Provide to Us. We collect personal information and non-personal information from you (such as your or your parents’ or guardians’ name, address, email address, phone number, credit card number, school name, grade level, year of graduation, date of birth, GPA, the test that you are interested in preparing for, test scores, academic interests, transcripts, photos, essays, applications to schools, employer name and job title, library card number, accommodation requests, race, and military or veteran status) when you:
- register or create an account on our Site;
- call us;
- purchase and use our products or services;
- provide or send us messages, documents, and other files and content in the course of your use of our products or services;
- enter sweepstakes or other promotions;
- submit online forms or testimonials and respond to surveys or questionnaires;
- register for or attend events we host, sponsor, or participate in; or
- when you provide us information by other means.
Information from Third Parties.
We may collect personal and non-personal information about you (such as your name, email address, student ID number, username, grade level, school name, and courses you are taking) from third parties with whom we have a business relationship (such as our organizational customers, organizations that we have marketing agreements with, resellers, licensees, franchisees, and service providers and other vendors who provide lead generation services).
We may receive information about you from our users who refer you to us and from college and universities for the purpose of conducting surveys.
We may obtain personal and non-personal information from publicly and commercially available sources, including organizers of events you may attend.
Information Collected Automatically.
We collect information (such as your IP address, machine ID, your browser type, cookies, the referring website address, and operating system) from your browser when you visit our Site.
We, our service providers and other vendors, and our affiliates and third parties may use tracking technologies such as cookies to collect information about your online interactions with our Site and our emails.
We collect information when you purchase or use our products and services (such as when we record online sessions or presentations, produce transcripts of online tutoring sessions, and track the drills and practice tests that you take online).
We automatically record calls to our call center.
How We Use Information
We may use your personal information to:
- provide you with and personalize our products and services;
- create and manage your account, process your orders, and provide you customer service;
- maintain our internal records and otherwise manage our business;
- send you newsletters and advertisements and otherwise correspond with you about products, services, events, and other organizations that we think may interest you or, if an organizational customer arranged for your participation in our programs, send you newsletters and otherwise correspond with you about our products, services, and events that we think may interest you;
- ask for your reviews and testimonials and send you surveys and questionnaires;
- administer sweepstakes and other promotions;
- develop and display content and advertising tailored to your interests on our Site and other sites, provide our advertisements to you when you visit other sites, and analyze the effectiveness of our advertisements or, if an organizational customer arranged for your participation in our programs, develop and display content tailored to your interests on our Site;
- perform research and analysis about your use of or interest in our products and services, the products or services offered by others, and our Site, and develop new products and services (unless an organizational customer arranged for your participation in our programs);
- detect, prevent, or investigate illegal activity or misuse of our products or services and enforce our legal rights; and
- perform functions as otherwise described to you at the time of collection.
We may use non-personal information for any lawful purpose.
Third Parties to whom We Disclose Information
We may disclose your information to third parties as described below. We do not disclose your personal information to third parties for their direct marketing purposes except as described under “Schools You are Interested in” and “Licensees and Franchisees” below.
Organizations and Persons who Arrange for Your Participation in Our Programs
We work with schools, school districts, colleges and universities, local, state, and federal government agencies, businesses, and other organizations to provide programs such as tutoring, test preparation, and college admissions counseling. Your organization may arrange for your participation in these programs and negotiate a special price or trial offer, or purchase (or subsidize) products or services on your behalf. We may disclose your personal and non-personal information that we collect through your participation in these programs (such as test scores, transcripts or recordings of online tutoring and online class sessions, comments you leave in post-session surveys, and details regarding your usage of our programs) to the organization arranging for your access to these programs or with your parents or guardians. In addition, your school may require us to disclose such information to others legally entitled to access your academic records, such as your state department of education. If you use a promotion code at our Site to create an account or add products or services, we may let the source of that promotion code know that you used that code.
Service Providers and Other Vendors
We may disclose your personal information to our service providers and other vendors, such as those who provide tools for communicating and exchanging information with customers, help us manage our relationships with customers, process transactions, license content to us, provide instruction, produce and deliver materials to customers, help us market our products and services, provide tools for online forms and surveys, analyze online activity, provide online hosting and storage services, and otherwise help deliver our products and services and operate our business.
Schools that Provide Classrooms for Courses
We may disclose your name to the school, as may be required by the school, that provides the classroom for the course in which you enroll.
Schools You are Interested in
You may direct the disclosure of your personal information to the schools on our Site for their direct marketing purposes by selecting “Connect with School” or “Request Info” next to the schools on our Site or selecting “Select All Schools” from the search results of schools that match your interests. If you do not want to direct the disclosure of your personal information with the schools, do not select the options listed above.
Licensees and Franchisees
If you are located outside the United States and Canada, we may disclose your personal information to our licensees and franchisees in your location who may market their products and services to you. If you uncheck “I’d like to receive promotional offers, informative content, product updates and more” under your account settings for The Princeton Review, then we will stop such disclosure, but licensees and franchisees who previously received your personal information may continue to market their products and services to you.
Affiliates
We may disclose your personal information to our affiliates.
Legally Compelled Disclosures and Safety
We may disclose personal information when compelled to do so by government authorities or otherwise as required or permitted by law, such as to respond to court orders and subpoenas. We may also disclose personal information to protect the safety of others and when we have reason to believe that someone is causing injury to or interfering with our rights or property or the rights or property of others.
Business Transfer
If we or all or a portion of our business is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, personal information may be included in the transferred assets.
Authorized Disclosure
We may disclose your personal information to third parties when you authorize the disclosure.
Non-Personal Information
We may disclose non-personal Information to any third party for any lawful purpose.
Your Access to Information
If you have an account with us, you may review and correct the information that is accessible to you under the settings for your account on our Site or by calling 800-2REVIEW.
Opting Out of Promotional Correspondence
You may elect not to receive promotional correspondence from us. If you have an account with us, you may make this request under the settings for your account by indicating which correspondence you would like to receive. You can also send an e-mail to prep@review.com . In this e-mail, please say whether: (i) you would like to opt out of receiving all e-mail promotional correspondence from us in general or (ii) if you would only like to opt out of certain of our e-newsletters or correspondence and if so which ones or (iii) you would like to opt out of receiving SMS or text messages. You may also opt out of our promotional e-mails by clicking on an opt-out link within the e-mail you receive.
Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
Using Caution when Sharing Information with Others
When you contribute to a public area or feature of our Site, such as a chat room, bulletin board, list serve, blog, or wiki, the information that you submit will be made available to the general public. Therefore, we recommend that you do not submit any sensitive information to such areas of our Site, including your full name, home address, phone number, financial information or any other information that would enable other users to locate you or contact you.
Other Sites
When you are on our Site, you may be able to visit or link to other sites not operated by us. We do not control such sites and are not responsible for the information practices of these sites. This Privacy Policy does not address the information practices of those other websites, and we encourage you to read the posted privacy policies of such sites.
California Consumer Privacy Act and California Privacy Rights Act Rights
The information in this California Consumer Privacy Act and California Privacy Rights Act Rights section applies only to California consumers. Any terms defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“California Privacy Law”) have the same meaning when used in this California Consumer Privacy Act and California Privacy Rights Act Rights section.
Personal Information (Including Sensitive Personal Information) We Collect
We may collect, and in the past 12 months have collected, the following categories of personal information:
- Identifiers (such as name, address, email address, cookies, IP address, machine ID, date of birth, student ID number, and library card number)
- Categories of personal information listed in the California Customer Records statute (such as phone number, credit card number, and education)
- Characteristics of protected classifications under California or federal law (such as military or veteran status and race)
- Commercial information (such as purchase history)
- Internet or other electronic network activity information (such as interaction with our Sites)
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (such as test scores, GPA, course enrollments, and transcripts)
- Audio, electronic, visual, thermal, olfactory, or similar information (such as recorded voice, recorded video, and photos)
- Professional or employment-related information (such as employer information and job title)
- Inferences drawn from other categories of personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes (such as likelihood of making a purchase based on internet or other electronic network activity)
- Sensitive personal information:
- Social security number (which we may collect from consumers who are winners of giveaways and (if they choose to provide the information to us, even though we do not intend to collect such information) from consumers enrolled in our admissions counseling services)
- Account log-in in combination with any required security or access code, password, or credentials allowing access to an account.
- Financial account, debit card, or credit card number in combination with any required security or access code
- Racial or ethnic origin
- Religious or philosophical beliefs (which we may collect from consumers enrolled in our admissions counseling services and take into account in providing our admissions counseling services (if they choose to provide the information to us, even though we do not intend to collect such information))
- Personal information collected and analyzed concerning a consumer’s health (which we may collect from consumers enrolled in our admissions counseling services and take into account in providing our admissions counseling services (if they choose to provide the information to us, even though we do not intend to collect such information))
- Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation (which we may collect from consumers enrolled in our admissions counseling services and take into account in providing our admissions counseling services)
Sources from which Personal Information (Including Sensitive Personal Information) is Collected
We collect personal information from the categories of sources listed below, as described in more detail in the “Information We Collect” section above:
- Consumers
- Third parties with whom we have a business relationship (such as our organizational customers, organizations that we have marketing agreements with, resellers, licensees, and franchisees)
- Other users who refer you to us
- College and universities who provide information for the purpose of conducting surveys
- Publicly and commercially available sources, including organizers of events you may attend
- Browsers and tracking technologies
- Our service providers and other vendors
Purposes for which Personal Information (Including Sensitive Personal Information) Will Be Collected or Used
We may collect or use personal information for the following purposes:
- provide you with and personalize our products and services;
- create and manage your account, process your orders, and provide you customer service;
- maintain our internal records and otherwise manage our business;
- send you newsletters and advertisements and otherwise correspond with you about products, services, events, and other organizations that we think may interest you;
- ask for your reviews and testimonials and send you surveys and questionnaires;
- improve our products, services, and Site;
- administer sweepstakes and other promotions;
- develop and display content and advertising tailored to your interests on our Site and other sites, provide our advertisements to you when you visit other sites, and analyze the effectiveness of our advertisements;
- perform research and analysis about your use of or interest in our products and services, the products or services offered by others, and our Site, and develop new products and services;
- detect, prevent, or investigate illegal activity or misuse of our products or services and enforce our legal rights; and
- perform functions as otherwise described to you at the time of collection.
We do not use sensitive personal information for purposes other than to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
Personal Information Sold
We may be deemed to sell personal information (but not sensitive personal information) to third parties who provide online advertising services to us for the purpose of cross-context behavioral advertising and may be deemed to have sold personal information of California consumers in the preceding 12 months to third parties who provide online advertising services to us for the purpose of cross-context behavioral advertising. The foregoing does not apply to consumers who visited www.tutor.com but not www.princetonreview.com. We do not currently sell the personal information of minors under 16 years of age and do not have actual knowledge that we sell the personal information of minors under 16 years of age. We do not have a process for those under 16 years of age to opt-in to such sharing.
Personal Information Shared with Third Parties
We have shared personal information (but not sensitive personal information) with third parties who provide online advertising services to us for the purpose of cross-context behavioral advertising in the preceding 12 months. The foregoing does not apply to consumers who visited www.tutor.com but not www.princetonreview.com. We do not currently share the personal information of minors under 16 years of age and do not have actual knowledge that we share the personal information of minors under 16 years of age. We do not have a process for those under 16 years of age to opt-in to such sharing.
Personal Information (Including Sensitive Personal Information) Disclosed for a Business PurposeWe may disclose personal information to a third party for a business purpose. In the preceding 12 months, we have disclosed the categories of personal information listed below:
- Identifiers
- Categories of personal information listed in the California Customer Records statute
- Characteristics of protected classifications under California or federal law
- Commercial information
- Internet or other electronic network activity information
- Non-public education information
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional or employment-related information
- Inferences drawn from other categories of personal information
- Sensitive personal information
We have disclosed some of the categories of personal information to organizations which arranged for consumers’ participation in our products and services as part of the services we provide to these organizations. We have disclosed all of the categories of personal information listed above to our service providers and other vendors because they help deliver our products and services and otherwise help us operate our business.
We do not disclose sensitive personal information to third parties for purposes other than to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
Your Right to Know
You have the right to request that we disclose information to you about our collection, use, disclosure, sale, and sharing of your personal information. Once we receive and confirm your verifiable consumer request, then subject to exceptions provided under the California Privacy Law and based on your request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources from which we collected your personal information.
- The business or commercial purpose for collecting, selling, or sharing your personal information.
- The categories of third parties to whom we disclosed your personal information.
- The specific pieces of personal information we collected about you.
- If we sold or shared your personal information, the categories of personal information that we collected about you and that were sold or shared with each category of recipient.
- If we disclosed your personal information for a business purpose, the categories of personal information that we collected about you and that were disclosed to each category of recipient.
Your Right to Deletion
You have the right to request that we delete your personal information that we have collected, subject to exceptions provided under the California Privacy Law. Once we receive and confirm your verifiable consumer request, then unless an exception applies, we will delete your personal information from our records and direct our service providers and other vendors to delete your personal information from their records.
Your Right to Correct Inaccurate Personal Information
If we maintain inaccurate personal information about you, you have the right to request that we correct the inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. Once we receive and confirm your verifiable consumer request, then unless otherwise provided by the California Privacy Law and subject to our receipt of documentation that we may request, we will correct your personal information in our systems and direct our service providers and other vendors to correct your personal information in their systems. Please note, however, that if we received the inaccurate personal information from an organization that arranged for your participation in one of our programs, then the organization may need to correct the inaccurate personal information in order for you to be able to continue to access the program.
Submitting Requests
To exercise your right to know, right to deletion, or right to correction described above, please submit a verifiable consumer request to us by:
- Calling us at 888-223-7737; or
- Completing and submitting the web form located at www.princetonreview.com/ccpa or www.tutor.com/ccpa
You may only make a verifiable consumer request to know twice within a 12-month period.
You may authorize another person to act as your agent to submit requests on your behalf. Unless you provide the agent with power of attorney under the California Probate Code, you will need to provide the agent a written and signed authorization. You may also submit requests on behalf of your minor child.
Verification
We will verify your identity before fulfilling your request to know, to delete, or to correct. If you have an account with us, we will ask you to enter your username and password through a link we provide to verify your identity. If you do not have an account with us, we will ask you to provide us data points that we have about you to verify your identity.
If you authorize another person to act as your agent to submit requests on your behalf, then unless you provide the agent with power of attorney under the California Probate Code, we will ask the agent to provide us the written and signed authorization that you provided to the agent, we will confirm with you that you did provide the authorization, and we will verify your identity. If you submit a request on behalf of a minor child, we will ask you to provide us information about your child that allows us to determine that you are the parent or guardian of the child. If the child is under the age of 13, we will ask you to sign a form declaring under penalty of perjury that you are the parent or guardian of the child.
Our Response to Your Request
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we reasonably require more time (up to 45 additional days), we will inform you of the reason in writing within 45 days of receipt of your request. We will deliver our written response by mail or electronically. If we are unable to comply with a request, our response will explain why.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive 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.
Your Right to Opt Out of the Sale and Sharing of Personal Information
You have the right to opt out of the sale of your personal information and sharing of your personal information for cross context behavioral advertising. You can exercise this right by clicking on the following link: www.princetonreview.com/cpraoptout . You can also exercise this right by calling us at 888-223-7737.
In your browser settings or through a browser extension, you can also have your browser send an opt-out preference signal. We will process the signal at the browser level so that when we detect the signal from your browser, we will opt you out of the sale and sharing of your personal information so long as you are using the same browser with the opt-out preference signal enabled.
The foregoing does not apply to consumers who visit www.tutor.com but not www.princetonreview.com since we do not sell or share the personal information of such consumers.
Your Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of the rights conferred by the California Privacy Law.
How Long We Retain Personal Information
The length of time that we retain each category of personal information is determined by various criteria, including maintaining our ability to provide our products and services and honor guarantees, contractual obligations, maintaining our ability to address complaints about our products and services and defend against or bring claims, maintaining records for audit purposes or as required by law, the type of relationship a consumer has with us and the duration of the relationship, and the retention policies and practices of, and features in the offerings provided by, our service providers and other vendors.
Processing of De-identified Data
We commit to maintaining and using de-identified data without attempting to re-identify the data.
Accessibility of this Privacy Policy
Commercially available screen reader programs should be able to read this Privacy Policy. As a web page, this Privacy Policy may be printed as a document.
Nevada Privacy Rights
We do not sell the personal information of Nevada consumers without their authorization, but Nevada consumers may submit an email to prep@review.com to request that we do not sell their personal information in the future.
Virginia Consumer Data Protection Act Rights
The information in this Virginia Consumer Data Protection Act Rights section applies only to Virginia consumers. Any terms defined in the Virginia Consumer Data Protection Act (“VCDPA”) have the same meaning when used in this Virginia Consumer Data Protection Act Rights section.
Categories of Personal Data that We Have Processed
We have processed the following categories of personal data:
- Identifiers (such as name, address, email address, phone number, cookies, IP address, machine ID, date of birth, student ID number, and library card number)
- Financial information (such as credit card number)
- Characteristics of protected classifications under federal law (such as military or veteran status and race)
- Commercial information (such as purchase history)
- Internet or other electronic network activity information (such as interaction with our Sites)
- Audio or visual information (such as recorded voice, recorded video, and photos)
- Professional or employment-related information (such as employer information and job title)
- Education information (such as test scores, course enrollments, graduation year, GPA, and transcripts)
- Sensitive data (such as personal data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, citizenship or immigration status, and personal data collected from a child known to be under the age of 13)
Purposes for Processing Personal Data
We may use personal data for the purposes listed under the “How We Use Information” section above.
How to Exercise Your Rights under the VCDPA
Subject to the VCDPA, you may exercise the following rights under the VCDPA:
- To confirm whether or not we are processing your personal data and to access such personal data;
- To correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data;
- To delete personal data provided by or obtained about you;
- To obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and
- To opt out of the processing of the personal data for purposes of targeted advertising. We do not engage in the sale of your personal data or in profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
To exercise any of these rights, please submit a request to us by completing and submitting the online request form located at www.princetonreview.com/vcdpa or www.tutor.com/vcdpa .
You may only make a request twice annually.
A parent or legal guardian who is known to us may submit requests on behalf of their child or ward under the age of 13.
We will verify your identity before fulfilling your request. If you have an account with us, we will ask you to enter your username and password through a link we provide to verify your identity. If you do not have an account with us, we will ask you to provide us data points that we have about you to verify your identity.
If you submit a request on behalf of a child or ward under the age of 13, we will ask you to provide us information about the child or ward that allows us to determine that you are the parent or guardian of the child or ward.
We endeavor to respond to a request after we have verified your identity within 45 days of receipt of the request. If we reasonably require more time (up to 45 additional days), we will inform you of the extension together with the reasons for the extension within 45 days of receipt of the request. If we decline to take action with respect to a request, we will provide a justification for our decision within 45 days of receipt of the request.
You may appeal our decision by completing and submitting an online appeals form located at www.princetonreview.com/vcdpaappeals or www.tutor.com/vcdpaappeals .
Within 60 days of our receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If you disagree with our decision, you may contact the Attorney General of Virginia to submit a complaint at www.oag.state.va.us or 800-552-9963.
We do not charge a fee to respond to your requests unless your requests are manifestly unfounded, excessive, or repetitive. 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.
Categories of Personal Data that We Share with Third Parties
We may share any of the personal data that we process with third parties.
Categories of Third Parties with whom We Share Personal Data
We share personal data with the categories of third parties listed under the “Third Parties to whom We Disclose Information” section above.
Targeted Advertising
We process personal data for targeted advertising. You may opt out of such processing by submitting a request to us under the “How to Exercise Your Rights under the VCDPA” section above.
Processing of De-identified Data
We commit to maintaining and using de-identified data without attempting to re-identify the data.
Users Outside of the United States
By providing personal information to this Site, you understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories, in accordance with applicable law. We operate in and market to individuals primarily in the United States and Canada, and we do not operate in or market to individuals in the European Economic Area or the United Kingdom. The processing by us of personal information of individuals outside of the United States or Canada is generally incidental. We do, however, recognize the privacy-related rights of individuals in countries which provide such rights, and therefore, request that any such individuals who have questions about or requests related to the personal information we collect to contact us at prep@review.com .
Changes to this Privacy Policy
We will update this Privacy Policy from time to time. When we post changes to this Privacy Policy, we will revise the “Effective Date” at the top of this Privacy Policy. We recommend that you check our Site from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.
Contact Us
If you have any questions or comments regarding this Privacy Policy or our privacy practices, you may contact us by email or mail at the following address:
The Princeton Review and Tutor.com
110 E. 42nd Street, 7th Floor
New York, NY 10017
Attention: Legal Department