Please click here to view the previous version of our Privacy Policy.

California Notice at Collection/State Law Privacy Rights: See the State Law Privacy Rights section below for important information about your rights under applicable state privacy laws.

Juni Learning, Inc. d/b/a Acely and our affiliates and subsidiaries (“Acely,” “we“, “us” or “our“) provide an online platform that prepares high school students for the SAT, PSAT, ACT, AP tests, and other exams. This Privacy Policy describes how Acely processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website and social media pages) as well as our marketing activities, live events, and other activities described in this Privacy Policy (collectively, the “Service”). Acely may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

Index

• Personal information we collect
• Tracking Technologies
• How we use your personal information
• Your choices
• How we share your personal information
• Other sites and services 
• Security
• International data transfers
• Children
• Changes to this Privacy Policy
• How to contact us
• Acely’s Terms of Use

 

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
• Demographic data, such as your city, state, country of residence, the school you attend, postal code, and age.
• Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, redemption code, biographical details, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.  
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise. 
• Subscription data, such as information relating to or needed to service your subscription to the Service, including subscription tier and transaction history. 
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content data, such as written responses; practice data; score data; essay drafts; comments, questions, and messages, including with Acely’s AI chat; works of authorship; and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data. 
• Relationship data, such as familial or other relationships to third parties whose personal information you may provide to us.
• Payment data needed to complete transactions, including payment card information or bank account number.
• Promotion data, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity, determine your eligibility, or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Data providers, such as information services and data licensors. 
• Partners, such as marketing partners and event co-sponsors.
• Customers
• Service providers that provide services on our behalf or help us operate the Service or our business.
• Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Precise geolocation data when you authorize the Service to access your device’s location.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open or forward emails). We may do this through the use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 

For more information concerning our automatic collection of data, please see the Tracking Technologies section below.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

Tracking & Other Technologies

Cookies and other technologies. Some of our automatic data collection is facilitated by cookies and other technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

Chat and other artificial intelligence (“AI”) technologies, such as those provided by OpenAI, Anthropic, and Intercom that employ cookies and software code to operate the features that we use to tailor your study plan, grade your responses, analyze your performance, and provide customer support through the Service. OpenAI, Anthropic, Intercom, and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats or within inputs to facilitate the provision of the Service.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section of our Cookie Notice.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide the Service and operate our business;
• enable security features of the Service;
• establish and maintain your user profile on the Service;
• facilitate your invitations to friends who you want to invite to join the Service;
• facilitate social features of the Service, such as by creating leaderboards, identifying and suggesting collaborative study experiences with other users of the Service, and providing chat or messaging functionality;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; 
• communicate with you about events in which you participate; and
• provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

• understand your needs and interests;
• personalize your experience with the Service and our Service-related communications; and
• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For more information on analytics, see our Cookie Notice. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes: 

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.  
• Interest-based advertising. We, our service providers, and third-party advertising partners may use cookies and other technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that we or they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice. 

Events, promotions, and contests. We may use your personal information to: 

• administer promotions and contests;
• communicate with you about promotions or contests in which you participate; and
• contact or market to you after collecting your personal information at an event.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
• audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
• enforce the terms and conditions that govern the Service; and 
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified or anonymized data. We may create aggregated, de-identified or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business, and to train our AI models and for other machine learning purposes.  

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

How we share your personal information

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).  

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, AI providers, such as providers of generative AI technologies such as OpenAI, email delivery, marketing, consumer research and website analytics). 

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy. 

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. 

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. 

Education partners. Third parties through whom the Service is offered, such as third-party tutoring services or schools.

Business and marketing partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in us, financing of us, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of us as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Your Profile data and some user-generated content may be visible to other users of the Service and the public. For example, other users of the Service may have access to information regarding your score data if you earn a place on our leaderboard and/or choose to share your practice stats. As another example, if you choose to provide a testimonial, your name and other user-generated content data may be visible to other users of the Service and the public. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices 

In this section, we describe the rights and choices available to all users. For more information on choices available to users based on where they live, please see our U.S. State Privacy Rights Notice.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. 

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. You may opt-out of text messages by texting “STOP” in response to a text that you receive or by other reasonable means.

Cookies and other technologies. For information about cookies and other technologies employed by the Service and how to control them, see our Cookie Notice. 

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security 

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. 

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children

If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child under the age of 13 in the United States or, where applicable outside of the United States, the age of 16, without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

• Email: [email protected] 
• Mail: 2261 Market Street, #4242, San Francisco, CA 94114
• Phone: +1 650-977-3418

U.S. State Privacy Rights Notice

Except as otherwise provided, this section applies to residents of California and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).

This section describes how we collect, use, and share for the purposes of targeted advertising Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if your state does not afford you these rights, you may not be able to exercise these rights. In addition, we may not be able to process your access, correction or deletion request if you do not provide us with sufficient detail to allow us to confirm your identity and understand and respond to your request.

For purposes of this section, the term “Personal Information” means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device. In some cases, we may provide a different privacy notice to certain categories of residents of certain states, such as job applicants, in which case that notice will apply instead of this section.

We do not re-identify personal information that is de-identified. 

Your privacy rights. You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law.

• Information. You can request to know whether we process your personal information. You can also request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting, selling, and/or sharing Personal Information for targeted advertising purposes.
  • The categories of personal information that we sold or shared for targeted advertising purposes, and the categories of third parties to whom this information was sold or shared, categorized by the type of personal information for each type of third party.
  • The categories of personal information that we disclosed for business purposes and the types of entities to whom this information was disclosed.
  • The specific third parties to which we have disclosed personal information.
•  Access. You can request a copy or representative summary of the Personal Information that we have collected about you. 
• Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
• Deletion. You can ask us to delete the Personal Information that we have collected from or about you.
• Revoke consent. You may have the right to revoke your consent to our processing of your personal information.
• Opt-out
  • Opt-out of certain processing for targeted advertising purposes. We may process Personal Information for targeted advertising purposes. You can opt out of the sharing of your Personal Information for targeted advertising purposes and any other processing deemed a sale under applicable law.
  • Opt-out of profiling/automated decisionmaking. We do not use your Personal Information to engage in automated processing or profiling Personal Information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements to make a decision that produces legal or similarly significant effects.   
• Consumers under 18. We may sell or share the personal information of consumers under 18 years of age. If we know that you are 13-18 years of age, we will ask for your affirmative authorization to share your Personal Information for targeted advertising purposes before we do so. If we know that you are under 13 years of age, we will ask for your parent or guardian’s affirmative authorization to share your Personal Information for targeted advertising purposes before we do so. We do not knowingly sell share the Personal Information of Maryland consumers under the age of 18 for targeted advertising purposes.
• Sensitive Personal Information
  • California Residents: Limit processing of Sensitive Personal Information. We may collect certain categories of Sensitive Personal Information as described in this Privacy Policy. We use Sensitive Personal Information as necessary for certain business purposes, including providing goods or services as requested; ensuring safety, security; and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual. While we process certain categories of Sensitive Personal Information as described in this Privacy Policy, we do not process Sensitive Personal Information for purposes beyond those listed above.
  • Residents outside California: Sensitive Personal Information.  You can opt-out of our processing your Sensitive Personal Information by electing not to provide it to us or by notifying us of your opt-out.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.  
• Appeal. You can appeal our denial of any request validly submitted. 

Exercising your right to information/know, access, correction, deletion, and appeal. You may submit requests at link to webform, calling us toll-free at 1-650-977-3418, or via email to [email protected].  

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Exercising your right to opt-out of/revoke your consent to the “sale” of your personal information or “sharing” of your personal information for targeted advertising purposes.  You can submit requests to opt-out of targeted advertising and other “sales” or “sharing” of personal information (as defined by applicable State Privacy Laws) here: Cookie Preferences, via email to [email protected] or by broadcasting the Global Privacy Control signal. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/. These signals set your opt-out preferences only for the particular browser or device you are using and any consumer profile that we associate with that browser or device. 

Verification of Identity; Authorized agents. We may need to verify your identity to process your information/know, access, correction, deletion, or appeal requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury or other specific information that we think only you would have, where permitted by law.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the Personal Information we collect and may disclose to third parties by reference below to both the categories of Personal Information defined in the “Personal Information we collect,” “How we use your personal information,” and “How we share your personal information” sections of this Policy above and the categories of Personal Information specified in state law. This table describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

 

Retention Period for Personal Information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; 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; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it. 

Additional information for Connecticut residents. We do not collect, use, or sell personal data for the purpose of training large language models (“LLMs”).

Additional information for California residents.  

• Shine the Light law opt out. Under California’s Shine the Light law (California Civil Code Section 1798.83), we give you the right to opt-out of our disclosure of your personal information (as defined by this law) to third parties for their direct marketing purposes. You may send us requests to [email protected]. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. 

Additional information for Texas residents. NOTICE: We may sell your sensitive personal data, as defined by the Texas Data Privacy and Security Act, by using services that help deliver interest-based ads to you as described above.

Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale, as defined, of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email [email protected].

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section above.