Last updated: April 02, 2024 - 12:00:00AM UTCWelcome to our Privacy Policy! We're grateful for your interest in the Enrich community. iGrad, LLC ("iGrad", “Enrich”, “us”, “we”, or “our”) operates this website ( <a href="https://us.enrich.org">www.enrich.org</a> ) and other services that link to this Privacy Policy (collectively referred to as the “Services”). We take your right to privacy and the protection of your personal data very seriously.Our goal is to explain our Privacy Policy to you in the clearest and simplest terms possible. Should you have any question regarding our Privacy Policy or how we handle your personal data, please don’t hesitate to contact us at: privacy@igrad.com.&nbsp;This Privacy Policy informs you of our practices and policies regarding the collection, use, and disclosure of personal data (which we may also refer to as “personal information”) when you use our Services and the choices you have associated with that data. By using the Services, you agree to the collection and use of information in accordance with this policy. This Privacy Policy does not apply to any third-party websites, software, or applications that may integrate with our Services or perform services for us or on our behalf and require access to personal data and/or Usage Data (defined below) in order to serve their required function (“Third Party Services”) or any other third-party websites, software, applications, or businesses. If there are any aspects of this Privacy Policy that you do not agree with, please cease use of our Services (including our websites).&nbsp;

<h3>Services</h3>As we mentioned above, the Services is the Enrich website ( https://us.enrich.org ) and other services that link to this Privacy Policy, as well as all instances of the Services we provide as a Software-as-a-Service (“SaaS”) to our Partner Organizations defined below.<h3>Partner Organization(s)</h3>A Partner Organization is an organization (e.g. your school, employer, credit union, benefits provider, or another entity or person) that entered into an agreement with Enrich to provide (and configure) that organization’s instance of the Services to you, as well as affiliated organizations, such as resellers and/or the sponsor of your instance of the Services.&nbsp;<h3>Usage Data</h3>Usage Data is data that is collected automatically and generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).&nbsp;<h3>Third-Party Services</h3>Any third-party websites, software, or applications that may integrate with our Services or perform services for us or on our behalf and require access to your information and/or Usage Data in order to serve their required function.&nbsp;

<h3>&nbsp;</h3><h3>Information You, Your Partner Organization(s) or Other Third Parties Provide to Us</h3>&nbsp;While using our Services, we may ask you to provide us with certain personally identifiable (directly or indirectly) information that can be used to contact or identify you. This information may also be securely provided to us by your Partner Organization(s), for example, through a Single Sign On (“SSO”) endpoint.&nbsp;The information we collect depends on various factors, including, but not limited to the information provided by your Partner Organization(s), the configurations made to the instance of the Services provided to you by your Partner Organization(s), your choices to provide us with information during your usage of the Services, and our continually updated Services. Should you have any questions about the data your Partner Organization(s) collects or discloses to provide an optimal experience with our Services, please review your Partner Organization’s privacy policy or reach out to them directly.&nbsp;We may also allow you to check your credit score and credit report through our Services. If you choose to participate in that feature and request your credit score or report, we collect information you provide us to verify your identity, and we collect and request on your behalf your credit score and credit report information from a credit bureau partner, such as Equifax. We may also collect and use information from third parties, including your mobile carrier, to verify your identity.&nbsp;The following is the current list of categories of information, with examples of each, we may collect that you may choose to provide to us, your Partner Organization may choose to disclose to us or other third parties, such as a credit bureau partner, may provide to us (please see the section below on <a href="https://admin.igrad.com/Contents/Add/105948#use">How We Use Information</a> for details on how information about you is used.&nbsp;<ul><li>Account Related Information:&nbsp;Information such as email address, username, password, and other credentials you use to sign-in to use our Services, your account photo, your account settings, etc.&nbsp;</li><li>Contact and Biographical Information:&nbsp;Information such as your first and last name, email addresses, home addresses, phone number, Social Security number, driver’s license number, date of birth, etc.&nbsp;</li><li>Education Information: Information such as the name of your current, past, or intended school or Partner Organization(s); information about your student loans (e.g., loan type, balances, interest rate); your current or intended degree and school type; financial aid award letter; enrollment status; etc.&nbsp;</li><li>Career Information:&nbsp;Information such as the name of your current, past or intended employer or Partner Organization(s); your resume; your participation in and the details of your retirement plan, health plan, and other benefits; employment status filed or industry; career development goals; etc.&nbsp;</li><li>Financial Information:&nbsp;Information such as personal budget data (e.g. income, expenses, saving), general information about your credit cards excluding credit card number (e.g. credit card company/brand, balance, monthly payment), the types and dollar values for various assets and liabilities, your credit score, savings goals and progress, retirement goals and progress, types of bank accounts, insurance coverage etc.&nbsp;</li><li>Family and References Information: Information such as spousal income marital status; dependents status; family size; the references and next of kin that you provide, such as the first and last name; home address; phone number; email addresses; and the relationship of the reference or next of kin to you, etc.&nbsp;</li><li>Credit Score and Report Information: As stated above, if you request your credit score or credit report through our Services, we collect information you provide us to verify your identity and we collect and request on your behalf your credit score and credit report information from a credit bureau partner, such as Equifax.&nbsp;</li><li>Other Information You Provide Us:&nbsp;Information you provide us through online forms or other features, such as your comfort level with various financial topics, current or intended financial behaviors, indicators of personality type, financial stress level and stressors, etc. You may also provide us information about yourself via email, telephone or postal mail.&nbsp;</li></ul><h3>Information We Collect When You Use Our Services</h3>When you use our Services, we may also collect information regarding how the Services are accessed and used, such as Usage Data (defined above). The information we collect may include information such as your IP address, browser type, browser version, search queries you submit (such as content, scholarships and jobs searches, etc.), the pages of our Services that you visit, the objects you clicked, the content that you viewed, the time and date of your visit, the time spent on those pages, and other diagnostic data. The information we collect may also include geographical data, such as language, country, state, and city.&nbsp;We also collect content and other information you create or provide while interacting with our Services, such as content that you add to your favorites (e.g., content, courses, scholarships, etc.); content that you found helpful or unhelpful; your course scores and progress; action plan and Money Personality assessments; recommendations delivered via the Financial Wellness Checkup; progress and personalized outputs of interactive exercises and calculators; and questions, answers, and comments that you submit in the Community and comment areas of our Services.&nbsp;<h3>Information We Collect With Cookies</h3>We use cookies and similar tracking technologies to track the activity on our Services and hold certain information. Some cookies are associated with your account and information about you in order to personalize and provide our Services. Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies similar to cookies that we may also use are beacons, tags, and scripts to collect and track information and to provide, improve and analyze our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. Most browsers allow you to instruct your browser to refuse all cookies or to indicate when a cookie is being sent. You can also delete individual cookies from your browser. However, if you do not accept or if you delete cookies, you may not be able to use some portions of our Services. For more information about how we use cookies, please read our&nbsp;<a href="https://us.enrich.org/Cookies">Cookie Policy</a>.<h3>“Do Not Track” Signals</h3>The “do not track” (or “DNT”) concept has been promoted by regulatory authorities for the internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. Various web browsers offer a DNT option that sends a signal to websites visited by the user’s browser about the user's DNT preference. You can usually access your browser's DNT option in your browser's “preferences” or similar settings. As of the time of the posting of this Privacy Policy, there is no internet industry DNT technology standard. With regard to DNT, our websites and services do not currently respond to DNT signals in browsers because, as mentioned above, no DNT standard has been adopted. However, as we explain in this Privacy Policy, we take privacy and security seriously and you do have choices regarding how your browser handles cookies and other similar technologies.

We use the collected data for various, legitimate business purposes, such as to provide you with and maintain our Services, to fulfill the agreement entered into with your Partner Organization(s), and/or in adherence with legal obligations. More specifically, we use the information we collect and receive:<ul><li>To create your account and allow you to log in. If you choose to create an account using the Services sign up form, we will use the information provided to create your account and allow you to log in. If you choose to access our Services through Single Sign On (SSO) with a third-party account (such as the account you use with your Partner Organization), we use the information collected to create a seamless login experience and to personalize the experience of the Services for you.</li><li>To provide, update, maintain, and protect our Services and manage our contractual relationships. We use collected information to support delivery of our Services, prevent or address security and technical issues, and analyze and monitor usage and other activities. In support of the delivery of our Services, we may use information about you for purposes such as personalizing your experience (e.g., recommending relevant articles, videos, products or services, or using your name in website messaging), improving educational experiences (e.g., tailoring course content to better meet your goals and situation), providing you information you request (e.g., providing you your credit score and credit report, if you request) and enabling tools to help you achieve your goals (e.g., comparing student loan repayment options, projecting retirement savings, or saving your inputs to a budgeting tool for ease of use). As another example, with respect to credit report information you may request through our Services, we may use such credit report information or other information you have provided us to present offers and recommendations to you for financial and consumer products and services of third party marketing partners, and we may also use such credit report information or other information to prefill fields or answers to questions in online forms, tools, assessments, courses or other experiences or services we provide to you. We may also use your information to verify your identity and manage and comply with our contractual relationship with you and your Partner Organization(s).</li><li>To send emails and other communications. We may send you emails, messages, and other types of communications. These communications may include, but are not limited to information about the Services and its features, contests and other promotions, changes to our policies and Services, providing you with user support, and administrative communications. With the exception of administrative communications, such as resetting a password, you can opt-out of various categories of emails at any time by using the unsubscribe link(s) contained in the email. You may also opt out of all emails by contacting us at: privacy@igrad.com.&nbsp;</li><li>To serve targeted advertising and offers. We may use your information to display (or send to you) content, promotions, offers, and advertisements (from us or from our third-party partners) that are personalized to your needs, goals, interests, and/or situation.&nbsp;</li><li>To enable community related features and user-to-user communications. We may use your information to post questions or answers in our discussion forum(s), to display your first name and account photo in leaderboards and other features, to administer contests and sweepstakes, and/or to post testimonials.&nbsp;</li><li>To request feedback. We may use your information to request feedback to improve our Service.&nbsp;</li><li>To respond to your inquiries. We may use your information to respond to your inquiries and fulfill any of your requests.</li><li>To comply with applicable law. We may use your information as required by applicable law, legal process or regulation.&nbsp;</li><li>To enforce our terms, conditions, and policies. We may use your information to enforce our terms, conditions, and policies, such as our <a href="https://us.enrich.org/Terms">Terms of Service</a>.</li><li>For other purposed with your consent. We may use your information in any other way we may describe when you provide the information and for any other purpose with your consent.&nbsp;</li></ul>

We will retain your information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy. The criteria we use to determine our retention periods include:&nbsp;We will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.&nbsp;The length of time we have an ongoing relationship with you, Partner Organization(s) or other third parties in connection with providing your instance of the Services (e.g., for as long as you have an account with us or keep using our Services).&nbsp;We will also retain Usage Data for legitimate internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. When we have no ongoing legitimate business need to retain your information, we will delete or anonymize it.&nbsp;We may receive information about you from your Partner Organization(s) or other third parties (as we stated above) and we may retain that information consistent with this Privacy Policy after our agreement with your Partner Organization or other third party terminates. However, if our agreement with your Partner Organization or other third party requires us to delete information about you, we delete the information in accordance with that agreement.&nbsp;

<h3>&nbsp;</h3><h3>Business Transaction</h3>If we are involved in a merger, acquisition, asset sale or other similar transaction, your information may be transferred. We will provide notice before your information is transferred and becomes subject to a different Privacy Policy.<h3>Disclosure for Law Enforcement</h3>Under certain circumstances, we may be required to disclose your information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).&nbsp;<h3>Legal Requirements</h3>We may disclose your information in the good faith belief that such action is necessary:&nbsp;<ul><li>To comply with a legal obligation.&nbsp;</li><li>To protect and defend the rights or property of Enrich.&nbsp;</li><li>To prevent or investigate possible wrongdoing in connection with the Services.&nbsp;</li><li>To protect the personal safety of users of the Services or the public.&nbsp;</li><li>To protect against legal liability.</li></ul>&nbsp;<h3>Partner Organization</h3>We may disclose your information, except as noted below, to provide reporting to your Partner Organization(s). We may provide collected data via a reporting console, as well as through other secure transfer methods, to your Partner Organization(s) in order for them to provide you with services, analyze usage and efficacy, and for other uses determined by your Partner Organization(s).&nbsp;In the event you have requested your credit score or credit report information through our Services and we have collected that information on your behalf, we do not disclose your credit score or report information to your Partner Organization(s). However, we may disclose aggregated credit score or report information (e.g., averages and comparative groupings) to Partner Organization(s) or other third parties that is not linked or reasonably linkable to you individually.&nbsp;Should you have any questions about how your Partner Organization(s) is using your data, please review your Partner Organization’s privacy policy or reach out to them directly.&nbsp;<h3>Third-Party Services</h3>&nbsp;Overview&nbsp;We may disclose your information to Third-Party Services (defined above). Examples may include: using a calculator, email delivery, searching for a job, providing a resume critique, information you provide to verify your identity or for completing another transaction, translating content to another language or running analytics on Usage Data. These third parties have access to your information only to perform tasks, such as these, on our behalf and are obligated not to disclose or use it for any other purpose.&nbsp;TopResumeTopResume is a career services company that offers free resume analysis, as well as paid professional resume services. At your request and with your consent, we will send your first name, email, and uploaded resume to TopResume (which operates in the United States only), so that they may provide you with a free resume analysis. We encourage you to review <a href="https://www.topresume.com/privacy">TopResume's privacy policy</a> before accepting TopResume's analysis and services. In order to make a data or deletion request to TopResume, you can contact TopResume's Data Privacy team here: <a href="mailto:privacy@topresume.com">privacy@topresume.com</a>.&nbsp;Google AnalyticsGoogle Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is disclosed to other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from disclosing information to Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the <a href="https://policies.google.com/privacy?hl=en">Google Privacy Terms web page</a>.&nbsp;Other Users&nbsp;When you provide your information, such as adding a question or answer to a discussion group, or otherwise interact with community areas of our Services, your information may be viewed by all users, such as your account photo, first name, and/or comments.With Your ConsentWe may disclose your information for other purposes only when you offer your explicit consent.&nbsp;

The security of your data is of the utmost importance to us. Enrich has implemented reasonable organizational, technical, and administrative measures to protect against the loss, misuse, and alteration of personal information about users. As an example of technical measures we have implemented, we use encryption in the transmission of your personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure, and the safety and security of your information also depends on you. If you have a password for access to certain parts of our Services, you are responsible for keeping your password confidential. We ask you not to disclose your password to anyone.

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.&nbsp;If you are located outside the United States, please note that we transfer the data, including personal data, to the United States and process it there. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls and safeguards in place including the security of your data and other personal information. If you have questions about the transfer of your data or the controls and safeguards we have in place, you can email us at privacy@igrad.com.

<h3>&nbsp;</h3>Your RightsIf you are a resident of the European Economic Area (“EEA”), you have certain data protection rights under the General Data Protection Regulation (“GDPR”). Subject to any exemptions provided by law, we aim to take reasonable steps to allow you to correct, amend, or delete your personal data. You can usually do this using your Account Settings and/or other features within the Services. You can also contact us at privacy@igrad.com to be informed what personal data we hold about you, and/or if you would like us to correct, amend, or delete your personal data.In certain circumstances, your rights under the GDPR include the following:The right to access, update or delete the information we have about you. Whenever made possible, you can access, update or request deletion of your personal data directly within your Account Settings. If you are unable to perform these actions yourself, please contact us at privacy@igrad.com to assist you.The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.The right to object. You have the right to object to our processing of your personal data. Your right to object includes the right to object at any time to the processing of your personal data for direct marketing purpose.The right of restriction. You have the right to request that we restrict the processing of your personal information.The right to data portability. You have the right to be provided with a copy of the information we have about you in a structured, machine-readable and commonly used format.The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.Please note that we may ask you to verify your identity before responding to such requests. Please also note that our fulfillment of certain requests, such as requests to delete your information or restrict the processing of your information, may result in us being unable to provide you certain products or services.You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement if you think we are processing your personal data not in accordance with the GDPR. For more information, please contact your local data protection authority in the EEA.Legal BasisEnrich is located in the United States. Information we collect will be processed in the United States, and by using our Services you acknowledge and consent to the processing of your data in the United States. The United States is not subject to a finding of “adequacy” from the European Commission under Article 41 of the GDPR and iGrad has not self-certified its participation in the EU-U.S. Data Privacy Framework. Accordingly, we rely on derogations set forth in Article 44 of the GDPR. If you are in the EEA, our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal data we collect and the specific context in which we collect it, as we discuss above in this Privacy Policy. We process your information in the United States: with your consent, to perform a contract with you or your Partner Organization, or because we have compelling legitimate interests as a company, such as to determine the effectiveness of our Services, to operate, improve and renew our Services, to protect our or the rights, property or safety of others, and for general research and analysis purposes. When processing personal data for our legitimate interests, we take appropriate measures to ensure that the interests we have are not outweighed by your interests or fundamental rights and freedoms. We may also process your personal data in order to comply with a legal obligation or to protect your vital interests.

Our Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.&nbsp;

Our Services are not directed to or intended for anyone under the age of 13 or anyone under age 16 in Europe ("children" or “child”). We do not knowingly collect personal information from children under age 13 or children under age 16 in Europe. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected the personal information of a child or that a child has registered an account with us without verification of parental consent, we take steps to delete that information and deactivate any user account. Teenagers of ages 16 to 17 in Europe and ages 13 to 17 in the U.S. and elsewhere should encourage their parents to review this Privacy Policy and contact us with any questions or concerns.&nbsp;

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. If we make changes to the Privacy Policy that materially alter your privacy rights, we will provide additional notice via email and/or a prominent notice on our Services, and update the "effective date" at the top of this Privacy Policy. Before we use your personal information for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. If you disagree with any changes to this Privacy Policy, you have the right to withdraw consent and should do so using your Account Settings and/or other features within the Services. You can also contact us at privacy@igrad.com.

If you have any questions about this Privacy Policy, please contact us by email at privacy@igrad.com or by mail:&nbsp;iGrad, LLC&nbsp; Attn: Privacy&nbsp; 2163 Newcastle Avenue, Suite 100&nbsp; Cardiff-By-The-Sea, CA 92007&nbsp;

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