Privacy Policy

1. Information We Collect

We may collect the following categories of information, depending on how you use the Service:

1. Account information, such as name, email address, login credentials, account ID, age or age range, parent or guardian information, and consent records.
2. Test and learning information, such as practice test answers, scores, score estimates, percentiles, progress, skill analysis, weaknesses, study history, and reports.
3. College planning information, such as grade level, academic background, activities, intended majors, school lists, application preferences, essay drafts, writing samples, and related materials submitted by the user.
4. AI interaction information, such as prompts, questions, chat history, AI responses, feedback, generated content, and usage records.
5. Payment and transaction information, such as purchase history, subscription status, refund status, invoices, payment method metadata, and platform transaction records. We generally rely on third-party payment processors or app stores to process payments and do not intentionally store complete payment card numbers.
6. Device and usage information, such as IP address, device identifiers, browser type, operating system, app version, pages viewed, features used, log data, crash reports, and diagnostic information.
7. Communications information, such as customer support messages, emails, survey responses, feedback, and other communications with us.
8. Cookies and similar technologies, such as cookies, SDKs, pixels, local storage, analytics tools, and similar tracking technologies.

2. Sensitive Information

Users should avoid submitting highly sensitive information that is not necessary for the Service, such as passport numbers, government identification numbers, complete financial account information, medical records, precise home addresses, or other unnecessary sensitive data.

If a user chooses to provide sensitive information, we may process it only as necessary to provide the Service, comply with law, protect safety and security, or handle the user's request.

3. Information from Minors

The Service is primarily intended for high school students, parents, and users preparing to apply to U.S. colleges and universities. It is not designed for children under 13 to use independently.

If a user is under the age of majority where the user lives, the user should use the Service only with the consent and supervision of a parent or legal guardian.

If a user is under 13 years old, the user may not register for, purchase, or use the Service unless we have provided and completed a parental consent process that satisfies applicable legal requirements. If we learn or reasonably suspect that we have collected personal information from a child under 13 without required parental consent, we may delete, restrict, or disable the relevant account and information.

Parents or legal guardians who believe that a child under 13 has provided information without consent may contact us using the contact information below to request access, deletion, or restriction.

4. How We Use Information

We may use information to:

1. Provide, operate, maintain, and improve the Service.
2. Create and manage accounts, authentication, subscriptions, and user access.
3. Provide online tests, practice questions, explanations, reports, score analysis, and study recommendations.
4. Provide AI advisor features, essay suggestions, college planning, school selection suggestions, and related educational tools.
5. Process payments, subscriptions, refunds, chargebacks, invoices, and platform transactions.
6. Provide customer support, respond to inquiries, and handle disputes.
7. Personalize content, recommendations, learning paths, and product features.
8. Analyze usage, debug errors, test features, measure performance, and improve product quality.
9. Detect, prevent, and respond to fraud, abuse, account misuse, security incidents, and illegal activity.
10. Comply with legal obligations, platform rules, contracts, and requests from authorities.
11. Send service notices, important updates, policy changes, security alerts, and transactional messages.
12. Send product updates, educational content, promotions, or marketing communications where permitted by law and where the user has not opted out.

5. AI Services and Data Processing

The Service may use our own models or third-party AI models, cloud services, data processing tools, or APIs to provide AI advisor features, essay suggestions, college planning, test analysis, and other functions.

You understand and agree that:

1. Content entered by users may be transmitted to our servers or third-party service providers to generate AI responses or provide the Service.
2. We may log, analyze, quality-check, safety-review, debug, and improve AI interactions.
3. Where permitted by law, we may use de-identified, aggregated, or anonymized information to improve the Service, analyze trends, or develop features.
4. We require service providers to protect data in a reasonable manner, but third-party services may also be subject to their own terms and privacy policies.
5. AI responses may be incomplete, inaccurate, outdated, or unsuitable for individual circumstances, and users should not rely on AI responses as the sole basis for decisions.

6. How We Share Information

We do not sell personal information as our primary business model. We may share information as reasonably necessary to provide, maintain, process payments for, analyze, improve, and protect the Service, including with:

6.1 Service Providers

Cloud hosting providers, database providers, AI model providers, payment processors, analytics tools, customer support tools, email service providers, error tracking tools, cybersecurity providers, and other vendors that help us operate the Service.

6.2 Payment and Platform Services

If a user pays through the Apple App Store, Google Play, Stripe, PayPal, or another third-party platform, we may exchange transaction status, subscription status, refund status, and necessary billing information with those platforms.

6.3 Parents, Guardians, or Authorized Representatives

If a user is a minor, or if an account is managed by a parent, guardian, or authorized representative, we may provide account, payment, learning progress, test, or Service usage information to those persons where reasonably necessary.

6.4 Legal, Compliance, and Safety Purposes

We may disclose necessary information to comply with law, court orders, government requests, platform rules, to enforce our terms, protect our rights, resolve disputes, prevent fraud or abuse, or respond to security incidents.

6.5 Corporate Transactions

If we are involved in a merger, acquisition, investment, financing, asset transfer, restructuring, bankruptcy, or similar corporate transaction, user information may be transferred or disclosed as part of that transaction. We will require the recipient to protect the information under reasonable standards.

7. Data Retention

We retain information for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the Service, maintaining accounts, processing transactions, complying with legal obligations, resolving disputes, preventing fraud, enforcing terms, and improving the Service.

Different types of information may have different retention periods. For example:

1. Account information is generally retained for a reasonable period after account deletion.
2. Transaction and payment records may be retained for tax, accounting, and legal purposes.
3. Test and learning records may be retained to provide historical analysis, learning tracking, and product improvement.
4. Customer support records may be retained for dispute handling, quality management, and compliance purposes.
5. De-identified, aggregated, or anonymized information may be retained for longer periods where it cannot reasonably identify an individual.

8. International Data Transfers

The Service may be used by users in different countries or regions. We, our service providers, cloud hosts, AI model providers, or payment platforms may be located outside the user’s country or region.

By using the Service, you understand that your information may be transferred to, stored in, or processed in countries or regions outside where you live. Those places may have data protection laws that differ from the laws where you live. We will take reasonable safeguards as required by applicable law, such as contractual protections, data security measures, access controls, or other lawful transfer mechanisms.

9. Data Security

We use reasonable technical, administrative, and organizational security measures to protect information from unauthorized access, use, disclosure, modification, loss, or destruction.

However, no internet transmission, cloud storage, app, or electronic system can be guaranteed to be 100% secure. You understand and agree that we cannot guarantee absolute security, and use of the Service involves some risk.

Users are also responsible for safeguarding their accounts, passwords, login devices, and verification information, and should not share accounts with others.

10. Cookies and Similar Technologies

We may use cookies, SDKs, pixels, device identifiers, local storage, or similar technologies to keep users logged in, remember preferences, analyze usage, improve the Service, detect errors, prevent fraud, and optimize the product.

Users may be able to limit certain tracking technologies through browser, device, or operating system settings, but some features may not work properly as a result.

If we use tracking technologies for advertising, cross-app tracking, or cross-site tracking, we will obtain any required consent or provide opt-out choices as required by applicable law and platform rules.

11. Marketing Communications

Where permitted by law, we may send product updates, event information, promotional messages, educational content, or other marketing communications.

Users may opt out of marketing messages by following the unsubscribe instructions in the message or by contacting us. Even if a user opts out of marketing messages, we may still send necessary service notices, transactional messages, security alerts, policy updates, or account-related messages.

12. Children and Minors Privacy

The Service is primarily intended for high school students, parents, and users preparing to apply to U.S. colleges and universities. It is not designed for children under 13 to use independently.

If a user is under the age of majority where the user lives, the user should use the Service only with the consent and supervision of a parent or legal guardian.

If a user is under 13 years old, the user may not register for, purchase, or use the Service unless we have provided and completed a parental consent process that satisfies applicable legal requirements. If we learn or reasonably suspect that we have collected information from a child under 13 without required parental consent, we may delete, restrict, or disable the related account and information.

Parents or legal guardians who believe that a child under 13 has provided information without consent may contact us using the contact information in this Policy to request access, deletion, or restriction.

13. User Rights and Choices

Depending on where a user lives, the user may have rights to:

1. Know whether we process personal information about the user.
2. Access personal information.
3. Correct inaccurate or incomplete information.
4. Delete personal information.
5. Restrict or object to certain processing.
6. Request data portability.
7. Withdraw consent.
8. Opt out of marketing communications.
9. Appeal or challenge certain data processing decisions.
10. File a complaint with an applicable authority.

We may need to verify the user's identity before processing a request. Some information may not be deleted immediately because of legal obligations, transaction records, security, fraud prevention, dispute handling, contract performance, or other legitimate reasons.

14. California Privacy Notice

If a user is a California resident, the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA) may provide specific privacy rights, including the right to know, access, delete, correct, opt out of the sale or sharing of personal information, limit the use of sensitive personal information, and not be discriminated against for exercising privacy rights.

In the past 12 months, we may have collected the following categories of personal information:

1. Identifiers, such as name, email address, and account ID.
2. Commercial information, such as purchase history, subscription records, and transaction records.
3. Internet or electronic network activity information, such as usage records, device information, login records, and interaction records.
4. Education or admissions-related information, such as test records, scores, admissions background, and application preferences.
5. User content, such as essay drafts, AI conversation content, and customer support messages.
6. Inferences, such as learning analysis, skill diagnostics, and personalized recommendations.
7. Sensitive information, only to the extent voluntarily provided by the user and necessary for the Service or chosen by the user.

We use these categories of information to provide the Service, process payments, personalize features, provide AI advisor tools, analyze tests, support customers, protect security, improve products, comply with law, and handle disputes.

We do not sell personal information as our primary business model. If our future data use involves a "sale" or "sharing" as defined by California law, we will provide any required opt-out mechanism.

California residents may submit privacy requests using the contact information listed in this Policy. We will verify and process requests as required by applicable law.

15. EEA / UK Users

If a user is located in the European Economic Area or the United Kingdom, our legal bases for processing personal information may include:

1. Performance of a contract: providing accounts, tests, AI advisor features, payments, subscriptions, and customer support.
2. Legitimate interests: improving the Service, preventing fraud, maintaining security, analyzing usage, and handling disputes.
3. Legal obligations: complying with tax, accounting, consumer protection, regulatory, or legal requirements.
4. Consent: certain marketing, cookies, tracking, or sensitive information processing.
5. Vital interests or public interest: only where permitted and necessary under applicable law.

EEA / UK users may have rights to access, correct, delete, restrict processing, object to processing, request data portability, withdraw consent, and complain to a data protection authority.

16. Do Not Track Signals

Some browsers may offer Do Not Track signals. Because there is not currently a uniform industry standard for responding to Do Not Track signals, we may not respond to all such signals. Where applicable law or platform rules require choices or opt-out mechanisms, we will provide them as required.

17. Third-Party Links and Services

The Service may include links to third-party websites, application systems, payment platforms, school websites, the App Store, Google Play, or other external services. When users click or use third-party services, those third parties may collect or process information according to their own policies.

We do not control third-party data processing practices and are not responsible for third-party privacy policies, data security, or service content.

18. App Store and Google Play Privacy Disclosures

If the Service is offered through the Apple App Store or Google Play, we will provide app privacy labels, data safety information, or other privacy disclosures required by those platforms.

Users understand that privacy labels or data safety information shown in the App Store or Google Play are summaries presented in platform-specific formats. This Privacy Policy provides a more complete explanation of our data processing practices. If this Policy and platform disclosures are inconsistent, we will reasonably update the relevant disclosures to maintain consistency.

Apple requires developers to provide accurate and current information about an app's privacy practices, including data that may be collected by third-party SDKs. Google Play also requires developers to disclose data collection, sharing, and security practices. When submitting the App for review, the Privacy Policy, Apple privacy label, and Google Play Data Safety form should be kept consistent.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updated policies will be posted in the Service or provided by another reasonable method.

If a material change affects users' primary rights or our data processing practices, we will provide reasonable notice. A user's continued use of the Service after the policy update means the user understands the updated policy.

20. Contact Information

If you have questions about this Privacy Policy, personal information processing, data deletion, privacy rights, or security issues, please contact:

Company Name:

Pano Education

Support Email:

support@panoprep.com

Company Address:

221 N. Broad Street, Suite 3A, Middletown, DE 19709