EFFECTIVE: May 1, 2017

This Privacy Policy governs the manner in which Intervene Education System ('Intervene') collects, uses, maintains and discloses information collected from users (each, a 'User') of its www.intervene.io Site and any derivative or affiliated Sites on which this Privacy Policy is posted (collectively, the 'Site'). Please note that this Privacy Policy covers Intervene' practices regarding information collected from its Site.

The Information Intervene Collects

Like most website operators, Intervene collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose in collecting non-personally identifying information is to better understand how our visitors use our Site.

Additionally, certain visitors to Intervene' Site choose to interact with us in ways that require us to gather personally-identifying information. The amount and type of information that we gather depends on the nature of the interaction. Those who engage in transactions with us online – by purchasing packages of tutoring hours – are asked to provide additional information, such as the personal and financial information required to process those transactions. Intervene also collects potentially personally-identifying information like Internet Protocol (IP) addresses. We do not use such information to identify our visitors, however, and do not disclose such information, other than under the same circumstances that we use and disclose personally-identifying information, as described below. A User browsing the Site without registering an account or affirmatively providing personally identifiable information to Intervene does so anonymously.

Intervene may collect personally identifiable information from customers in a variety of ways. Personally identifiable information may include (i) contact data (such as a customer's name, mailing and e-mail addresses); (ii) financial data (such as amount purchased on our site) ; and (iii) demographic data (such as a customer's zip code, or school name). If you communicate with Intervene by e-mail; post messages to forums; make telephone or cell phone calls, communicate through electronic devices or other interactive devices; complete online forms, surveys or contest entries; or communicate with Intervene by any means, any information provided in such communication may be collected by Intervene. Intervene may also collect information about how customers use our Site, for example, by tracking the number of unique views received by the pages of the Site, or the domains from which customers originate.

Refer-A-Friend

Your friend may contact us at learn@p2g.org to request that we remove this information from our database.

Information Sharing

It is Intervene' policy to respect your privacy regarding any information we may collect through the Site, e-mail, phone, or any other communications we have with you. We treat the confidential information you share with us, such as students' academic performance and any financial information, with the utmost respect. Intervene will not disclose student records with third parties under any circumstance, except as required by applicable law.

We may, however, share a student's information with the tutor(s) who may or will be providing tutoring to the student so that they may evaluate the behavior, engagement and personalize and tailor the tutoring to the student. In each case, we collect such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor's interaction with Intervene. We do not disclose personally-identifying information other than as described below in the section 'How Intervene Uses Information'. We also do not collect personally identifying information on students. We only collect student first and last names, school, and teacher name at this time. Visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain Site-related activities.

Tracking Technologies

Intervene and our analytics and marketing providers use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the Site, track users' movements around the Site, and to gather demographic information about our User base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

We use cookies for for authentication. Each User can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve marketing, analytics, or site functionality.

LSOs

Third Parties, with whom we partner to provide certain features on our Site or to display advertising based upon your Web browsing activity, use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

Behavioral Targeting

How Intervene Uses Information

Intervene may use personally identifiable information collected through the Site for the specific purposes for which the information was collected; to contact Users regarding Intervene' live-learning platform; to communicate to Users regarding products and services offered through Intervene, its parent, subsidiaries, and trusted affiliates; and otherwise to enhance Users' experience with Intervene. Out of respect for your privacy, you may choose to stop receiving these marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at learn@p2g.org. Intervene may also use information collected through the Site for research regarding the effectiveness of the Site and the business planning, marketing, advertising and sales efforts of Intervene, its parent, subsidiaries, and trusted affiliates.

Intervene may disclose personally identifiable information collected from Users to its parent, subsidiaries and other related companies, trusted affiliates, independent contractors and business partners who will use the information for the purposes outlined above, as necessary to provide the services offered by or through Intervene and to provide the Site itself, and for the specific purposes for which the information was collected. These companies are not permitted to use your personally identifiable information in any other way.

Intervene may also disclose aggregate, anonymous data based on information collected from Users to investors and potential partners. Finally, Intervene may disclose or transfer personally identifiable information collected from Users in connection with or in contemplation of a sale of its assets or business or a merger, consolidation, or other reorganization of its business.

Correcting, Updating, Accessing or Removing Personal Information

To the extent applicable, if a User's personally identifiable information changes (such as a User's zip code), or if a User no longer desires to receive non-account specific information from Intervene, Intervene will endeavor to provide a way to correct, update, delete, and/or remove that User's previously-provided personal data. This can be done by emailing a request to Intervene at learn@p2g.org. Additionally, you may request access to the personally identifiable information as collected by Intervene by sending a request to Intervene as set forth above. We will respond to your request within a reasonable timeframe. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Legal Disclaimer

Intervene may disclose personally identifiable information at the request of law enforcement or governmental agencies or in response to subpoenas, court orders, or other legal process, to establish, protect, or exercise Intervene' legal or other rights or to defend against a legal claim or as otherwise required or allowed by law. Intervene may disclose personally identifiable information in order to protect the rights, property, or safety of a User or any other person. Intervene may disclose personally identifiable information to investigate or prevent a violation by User of any contractual or other relationship with Intervene or the perpetration of any illegal or harmful activity.

Security of Information

Intervene discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors, and affiliated organizations that (i) need to know that information in order to process transactions on our behalf or to provide tutoring services, and (ii) that have agreed not to disclose it to others. We take all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.

Information about each User that is maintained on Intervene' systems is protected using industry standard security measures. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at learn@p2g.org. However, no security measures are perfect or impenetrable, and Intervene cannot guarantee that the information submitted to, maintained on, or transmitted from its systems will be completely secure. Intervene is not responsible for the circumvention of any privacy settings or security measures relating to the Site by any User or third parties.

Your security is a priority and we strive to provide a safe and secure environment for our customers; however, please note that we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure. If you do not feel comfortable sending your financial/credit card over the Internet, contact us and we will be happy to fill your order over the phone.

Links to 3rd Party Sites

Please note that the Site may contain links to other Sites. These linked sites may not be operated or controlled by Intervene. Intervene is not responsible for the privacy practices of these or any other Sites, and you access these Sites entirely at your own risk. Intervene recommends that you review the privacy practices of any other Sites that you choose to visit.

Intervene is based, and this Site is hosted, in the United States of America. If User is from from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law and User is visiting, accessing, or otherwise using the Site, please note that any personally identifiable information that User provides to Intervene will be transferred to the United States. Any such personally identifiable information provided will be processed and stored in the United States by Intervene or a service provider acting on its behalf. By providing personally identifiable information to Intervene, User hereby specifically and expressly consents to such transfer and processing and the uses and disclosures set forth herein.

Social Media Widgets

Our Site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our Site. These Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Customer Testimonials / Comments / Reviews

We post customer testimonials/comments/reviews on our Site which may contain personally identifiable information. We do obtain the customer's consent via email or other means prior to posting the testimonial authorizing us to post their name along with their testimonial. To request removal of your personal information from testimonials/comments/reviews please contact us at learn@p2g.org.

Blogs

Anytime you post on our blog please be aware that you are posting using a third party application, and we have no access or control over this information.

To request removal of your personal information from our blog, you can either log into the third party application and remove your comment or you can contact the appropriate third party application. Your interaction with these features is governed by the privacy policy of the company providing it.

Tutor Profiles/Bios

If you apply as a tutor, the profile you create on our Site will be publicly accessible unless otherwise indicated. You may change the privacy settings of your profile and make it non-public through your account portal.

Import Contacts

You can import contacts from your Outlook or other email account address book to invite them to become members or Users of our Site. We collect the username and password for the email account from which you wish to import your contacts, and will only use your personal information for that purpose.

Children's Privacy

Intervene products are specifically designed to function without third party access to a child's personal information. Our Site does not collect or retain any personal information from children except as needed to facilitate tutoring for that student, who may be a minor. Intervene is committed to complying fully with the Children's Online Privacy Protection Act of 1998 ('COPPA'). This Site assures the privacy of collected information in accordance with the Intervene' Privacy Policy.

Intervene does NOT permit access to or the release, transfer, or other communication personally identifiable information contained in education records to any third party. See below for FERPA regulations: Under the FERPA regulations, "disclosure" means "to permit access to or the release, transfer, or other communication of personally identifiable information contained in education records to any party, by any means, including oral, written, or electronic means."34 CFR § 99.3 ("Disclosure") (emphasis added). The regulations define "personally identifiable information" so that it includes, but is not limited to: a. The student's name b. The name of the student's parent or other family member; c. The address of the student or student's family; d. A personal identifier, such as the student's social security number or student number; e. A list of personal characteristics that would make the student's identity easily traceable; or f. Other information that would make the student's identity easily traceable. 34 CFR § 99.3 ("Personally identifiable information") (emphases added). That is, FERPA-protected information may not be released in any form that would make the student's identity easily traceable.

Intervene is committed to safeguarding the information each User entrusts to Intervene and believes that every User should know how it utilizes the information collected from each User. The Site does not knowingly collect personally identifiable information from children under 13 years of age online. The Site allows Teacher and Administrator users to enter Student First, Middle and Last names with current Grade level and subject for registration. The system creates auto-generated student IDs for purposes of internal identification and connection on Intervene's platform. The Teacher Users of the Site may input student First, Middle, and Last names and may not, according to our Terms and Conditions of using the site, input any personally identifiable information for children under the age of 13 years.

Your California Privacy Rights

California Civil Code Section 1798.83 permits a User that resides in California to request certain information regarding Intervene' disclosures of personally identifiable information to third parties for such third parties' direct marketing purposes. If you are a California resident and would like to make such a request, please email Intervene at learn@intervene.io.

Changes to this Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting Intervene

If you have any questions or comments about this Privacy Policy, you may contact Intervene via any of the following methods:

Intervene 

PO Box 2144

Missouri City, TX 77459 
(855) 34-LEARN 

Email: learn@p2g.org