Introduction

Hippo Education, LLC (together with its officers, directors, employees, successors and assigns; the “Company,” “we,” “our”, “ours” or “us”) respects your privacy and are committed to protecting it through our compliance with this policy.

This policy (the “privacy policy”) describes the types of information we may collect from you or that you may provide, either directly or indirectly, when you visit any of our websites that link to this privacy policy (individually and collectively, the “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This privacy policy applies to information we collect:

• On the Website.

• In email, text, and other electronic messages between you and the Website.

• When you interact with our advertising and applications on third-party websites and applications, if those applications or advertising include links to this privacy policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any application or other website operated by any third party; or

• Any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this privacy policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices your choice is not to use the Website. By accessing or using the Website, you agree to this privacy policy. This privacy policy may change from time to time (see Changes to Our Privacy privacy policy). Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the privacy policy periodically for updates.

Children Under the Age of 13

The Website is not intended for children under 13 years of age. No one under the age of 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Website or through any of its features, register on the Website, use any of the interactive or public comment features of the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@hippoeducation.com.

California residents under 13 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of the Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number or any other information by itself or in combination with non-identifying information may be capable of personally identifying you (“personal information”); 

• That is about you but individually does not identify you, such as personal preferences, age, education, profession and hobbies; and

• About your internet connection, the equipment you use to access the Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on the Website or in relation to the use of our products and services. This includes information provided at the time of registering to use the Website, placing an order, subscribing to our services, posting material, requesting further services, and interacting with our products and services (including information you may provide as part of any retention, self assessment features associated with our products and services). We may also ask you for information when you report a problem with the Website.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out through the Website. 

• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on areas of the Website that may accessible or viewable by other users of the Website or may be transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on the Website and transmitted to others at your own risk. Although you may set certain privacy settings for such User Contributions by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to the Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website; and

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services. 

The information we collect automatically may include personal information, though it’s only used to help us to improve the Website and to deliver a better and more personalized service, including by enabling us to:

• Store information about your preferences, allowing us to customize the Website according to your individual interests.

• Decrease instances of fraudulent activity.

• Recognize you when you return to the Website.
• Identify and solve technical issues with our services.
• Estimate our audience size and usage patterns.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.

• Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

• Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third-parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information third-parties collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third-parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use Your Information; and, Disclosure of Your Information.]

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present the Website and its contents to you.
• To personalize your experience as you use the Website.
• To improve the content of the Website.
• To administer a contest, promotion, survey or other Website feature.
• To send periodic emails (which may be discontinued upon your request; we include unsubscribe instructions at the bottom of each email).

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to the Website or any products or services we offer or provide though it.

• To allow you to participate in interactive features on the Website.

• In any other way we may describe when you provide the information.
• To identify and resolve any issues with the Website.

• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at support@hippoeducation.com. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business.

• To a buyer or other successor in the event that the Company is subject to a merger, divestiture, restructuring, reorganization, dissolution, or sells all or substantially all of its assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Website users is among the assets transferred.

• To third parties to market their products or services to you. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to support@hippoeducation.com.

• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by unchecking the relevant notification box located on the User Settings page or by sending us an email stating your request to support@hippoeducation.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California residents may have additional rights and choices regarding their personal information. Please see Your California Privacy Rights for more information.  In addition, European Union citizens have rights and choices regarding their personal information. Please see Rights Under The General Data Protection Regulation for more information.

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Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at support@hippoeducation.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use (http://www.hippoed.com/terms).

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit [HYPERLINK TO CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS].

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@hippoeducation.com or write us at: Hippo Education, LLC, 1812 W. Burbank Blvd., #923, Burbank, CA 91506.

Rights Under The General Data Protection Regulation

If you are a citizen of the European Union, the General Data Protection Regulation (((EU) 2016/679), the “GDPR”) provides you with the following rights regarding the use and control of your personal information, subject to certain terms and conditions otherwise provided herein:

• The right to access.  You have the right to request the Company provide you copies of your personal information.  We may charge you a small fee for this service.

• The right to rectify.  You have the right to request that the Company correct any information you believe is inaccurate.  You also have the right to request the Company to complete information you believe is incomplete.

• The right to erasure.  You have the right to request the Company erase your personal information.

• The right to restrict processing.  You have the right to request that the Company restrict the processing of your personal information.

• The right to object to processing.  You have the right to object to the Company’s processing of your personal information.

• The right to data portability. You have the right to request that the Company transfer the data we collect to another organization, or directly to you.

If you make a request pursuant to your rights under the GDPR, we have one month to respond to you.  If you would like to exercise any of these rights, please contact us at support@hippoeducation.com.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All personal and transaction information on the Website is encrypted during transmission using Transport Layer Security (TLS) technology. During a transaction, your sensitive payment information (card number, etc.) is securely transmitted to our third-party payment gateway provider and is not stored on our systems. Your remaining order information is securely stored in our systems, and is only physically accessible to those individuals with special access rights.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. We will post any new, amended or updated privacy policy on this page either with or without notice that the privacy policy has been updated. If we make material changes to how we treat our users’ personal information, we will notify you at the primary email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting the Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: support@hippoeducation.com or via our toll-free number at 1-855-99-HIPPO.

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Privacy Notice for California Residents

Effective Date: June 1, 2019

This Privacy Notice for California Residents supplements the information contained in the privacy policy of Hippo Education, LLC (together with its officers, directors, employees, successors and assigns; the “Company,” “we,” “our” or “us”) which hyperlinks to this notice and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. 

Information We Collect

The Company’s website (the “Website”) collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, the Website has collected the following categories of personal information from its consumers within the last 12 months: 

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

The Company obtains the categories of personal information listed above directly from you (for example, from forms you complete or products and services you purchase) as well as indirectly from you (for example, from observing your actions on the Website).

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes: 

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns. 
• To provide, support, personalize, and develop the Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your experience on the Website and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of the Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve the Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization or dissolution of the Company, including the sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Website users is among the assets transferred.

The Company will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

The Company may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we require the recipient to both keep that personal information confidential and not use it for any purpose except performing the recipient’s obligations pursuant to the intended business purpose. 

We share your personal information with the following categories of third parties: 

• Service providers.
• Data aggregators.
• Professional organizations.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, Company has disclosed the following categories of personal information for a business purpose: 

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

Category K: Inferences drawn from other personal information.

Sales of Personal Information 

Company does not sell personal information to third parties.

Your Rights and Choices 

The CCPA provides California residents with specific rights regarding their personal information. This section describes the rights provided under the CCPA and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that the Company 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 (see Exercising Access, Data Portability, and Deletion Rights), 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 personal information categories that each category of recipient purchased; and 
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

Deletion Request Rights 

You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a request to us by either: 

• Calling us at 1-855-99-HIPPO
• Emailing us support@hippoeducation.com 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a request for access or data portability twice within a 12-month period. The request must:

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

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

Making a request does not require you to create an account with us.

We will only use personal information provided in a request to verify the requestor's identity or authority to make the request. 

Response Timing and Format

We endeavor to respond to a request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding the request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, 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. 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may from time to time offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer, as provided in our sole discretion, will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.    

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@hippoeducation.com.

Changes to Our Privacy Notice

The Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of the Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which the Company collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-855-99-HIPPO

Website: https://www.hippoed.com/contact

Email: support@hippoeducation.com

Postal Address: 
Hippo Education, LLC
1812 W. Burbank Blvd., #923
Burbank, CA 91506