VERTO CALIFORNIA PRIVACY NOTICE
Last Updated: 1/18/2023
1. Scope of Notice
This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California (“you”, “your”, “Consumer”, or “user”). Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Policy or as otherwise defined in the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”).
This CA Notice describes how Verto Education, Inc. (“Verto”) collects, uses, discloses, and otherwise processes Personal Information of individual residents of the State of California, either online or offline, within the scope of the CCPA and the CPRA, when Verto provides Consumers with the Service. This CA Notice does not apply to employment-related Personal Information about our employees, job applicants, contractors or similarly situated individuals.
2. Definitions
a. Consumer: As defined by the CCPA and CPRA, a “Consumer” is a natural person who is a California resident, living in California for other than a temporary or transitory purpose, or individual domiciled in California.
b. Personal Information. As defined by the CCPA and CPRA, “Personal Information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household.
c. Sensitive Personal Information. As defined by the CCPA and CPRA, “Sensitive Personal Information” is defined as information that if lost, compromised, or disclosed could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual. Sensitive Personal Information is a subset of Personal Information that requires greater security protections and standards of care in handling. Sensitive Personal Information includes information such as social security number, driver license number, state identification card, passport number, financial data, genetic data, biometric data, precise geolocation, and racial and ethnic origin, content of consumer communications (email, mail, or text), unless the business is the intended recipient, and information collected concerning a Consumer’s health, sex life, or sexual orientation.
3. Collection and Use of Personal Information
Below are the categories of Personal Information that we may have collected or shared for a business purpose in the last twelve (12) months, as permitted by law and depending on the products or services you receive:
| Category | Examples of Personal Information We May Collect | Collected | Retention Period |
| 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 | See Section 4 |
| B. Personal information categories listed in the California Customer Records statute | 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 | See Section 4 |
| 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 | See Section 4 |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES | See Section 4 |
| 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. | YES | See Section 4 |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES | See Section 4 |
| G. Geolocation data | Physical location or movements. | YES | See Section 4 |
| H. Sensory Data | Audio, electronic, visual, thermal, or similar information. | YES | See Section 4 |
| I. Professional or employment-related information | Employer, employment history, resumes and CVs, background checks, and other employment-related information. | YES | See Section 4 |
| J. Education Information | 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. | YES | See Section 4 |
| K. Inferences drawn from other Personal Information | Inferences drawn from any of the collected Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | YES | See Section 4 |
| L. Sensitive Personal Information | Social security, driver’s license, state identification card, or passport number. Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. Precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership. Genetic data. | YES | See Section 4 |
4. Retention
Verto stores the information we collect about you for as long as is necessary for the purpose(s) for which we collected it and in accordance with applicable law and legitimate business interests. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
5. Sources of Collecting Personal Information
Below are the sources from which we may receive your Personal Information:
- Directly from you and your family members (e.g. your parent or legal guardian);
- From third-party educational institutions, including Partner Colleges and Academic Providers;
- From third-party organizations from whom Verto may purchase Personal Information (e.g. College Board);
- From your browser or device;
- From information generated from your online browsing and usage activity;
- Service providers;
- Business partners and affiliates;
- High Schools and their counselors; and
- Third parties you direct to share information with us.
6. Business Purposes for Collecting Personal Information
We may collect, use or disclose Personal Information about you for one or more of the following business purposes:
- First and foremost, to provide you with the Service, including, without limitation, the Abroad Experience, any and all services contemplated pursuant to the various agreements entered into by and between you and Verto (including, without limitation, the Participation Agreement), and to otherwise fulfill our contractual obligations to you. This includes disclosing your Personal Information with our vendors and other service providers who need access to such Personal Information in order to complete work on our behalf (see How We Share Your Personal Data section of our Privacy Policy);
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about the Service, or to submit a complaint, we will use that Personal Information to respond to your inquiry;
- To communicate with you, including through email, text, or phone calls, to provide you updates, alerts, news and mailings relating to events that we think may be of interest to you relating to the Service;
- To market our Services to you, including through email, text, or phone calls;
- To send you statements and invoices in relation to any agreement between us to provide you with any part of the Service;
- To better understand the demographics of our Consumers;
- To recognize you and remember your information when you return to the Service;
- To help maintain the safety, security, and integrity of the Service, technology assets, and business;
- To protect the health and safety of our personnel and students, as well as any visitors to our premises (including the premises where Abroad Experiences are held);
- For research and analysis of the Service, including, without limitation, to further develop and improve the Service, including, without limitation, Verto’s Abroad Experiences, and other aspects of the Service;
- To assist you in sharing content from the Service with your friends, followers or contacts on a social network;
- To protect and defend the rights or property of Verto;
- When required by any applicable law, regulation or legal process; and
- In connection with any proposed merger, sale of company assets, financing, change of ownership or transfer of all or a portion of Verto’s business to another company.
7. Disclosure of Personal Information
In the previous 12 months, we have disclosed all of the categories of Personal Information we collect, explained in the Collection and Use of Personal Information section of this CA Notice, to third parties for a business purpose.
To learn more about the categories of third parties with whom we share Personal Information, please see the How We Share Your Personal Data section of our Privacy Policy.
When we disclose your Personal Information to a third party service provider, we enter into a contract with the third party service provider that describes the business purpose for which your Personal Information is disclosed and restricts the service provider from using your Personal Information for any purpose except performing the contract or as permitted by applicable law.
We do not sell your Personal Information or share your Personal Information with third parties for cross-contextual behavioral advertising purposes. We do not have actual knowledge that we sell or share Personal Information of minors under 16 years of age.
8. Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
a. The Right to Know, Access, Rectify, and/or Delete Personal Information
You may have the right to know, access, correct, and/or delete Personal Information about you which we have collected.
i. The Right to Know/Access: You have the right to request that we disclose the following about your Personal Information, as defined by the CCPA and/or CPRA:
- The specific Personal Information we may collect;
- The categories of Personal Information we may collect;
- The categories of sources from which we may collect your Personal Information;
- The business purpose(s) for collecting or sharing your Personal Information;
- The categories of Personal Information we may disclose for business purposes; and
- The categories of third parties to whom we may share your Personal Information.
ii. The Right to Correct: In certain circumstances, you have the right to request correction of any inaccurate Personal Information. Upon verifying the validity of a verifiable correction request, we will use commercially reasonable efforts to correct your Personal Information as directed, taking into account the nature of the Personal Information and the purposes of maintaining your Personal Information.
iii. The Right to Delete: You have the right to request that your Personal Information be deleted, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law, to continue to provide the Service, or for other legitimate business purposes.
b. The Right to Opt-out of the Sale or Sharing of Personal Information or De-identified Personal Information
As we do not sell or share your Personal Information, we do not offer an opt-out. However, if in the future we were ever to sell or share your Personal Information, you would have the right to opt-out of such use of your Personal Information.
c. The Right to Limit the Use of Sensitive Personal Information
As noted herein, depending on how you use the Service, we may collect certain Sensitive Personal Information from you. The use of such Sensitive Personal Information will be limited to that use that is necessary for us to provide the Service to you or perform our duties as required by CCPA and CPRA. For example, if you are participating in an Abroad Experience in a country that requires you to have a visa, we may request your passport (which is considered your Sensitive Personal Information) in order to help you obtain that visa. If in the future we should ever need to use your Sensitive Personal Information for any other purpose other than what is necessary for us to provide you with the Service, we will inform you and you shall have the right to limit the use of such Sensitive Personal Information used for purposes other than what is necessary for us to provide you with the Service.
d. The Right to Non-Discrimination
We will not discriminate or retaliate against you for exercising these consumer rights, including by (a) denying you goods or services; (b) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; or (c) providing you a different level or quality of goods or services (or suggesting that we will do so). However, the exercise of certain privacy rights will make it so that Verto is no longer able to provide you with certain aspects of the Service. For example, if you request that Verto delete your Personal Information, Verto will no longer be able to send you marketing communications about our Service that may be of interest to you.
9. How to Exercise Your California User Rights
To exercise the privacy rights described in Section 8 above, you may do either of the following:
- Fill out our California Resident Rights Request Form, or
- Call 1-888-520-2556.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as set forth in this CA Notice. Even if you choose to use an agent, as permitted by law, we may require you to confirm you have authorized the agent to act on your behalf or require you to verify your own identity.
10. Notice of Financial Incentive
We do not offer financial incentives to Consumers for providing Personal Information.
11. California’s “Shine the Light” Law
In addition to the rights described above, California’s “Shine the Light” law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of Personal Information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to [email protected]. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email address specified in this section.
12. Updates to This CA Notice
We reserve the right to amend this CA Notice at our discretion and at any time. When we make changes to this CA Notice, we will change the “Last Updated” date at the beginning of this CA Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.
13. Contact Us
If you have any questions or requests in connection with this CA Notice or other privacy-related matters, please send an email to [email protected].
