Privacy Policy

Last Updated: August 14, 2024

This Privacy Policy explains how Verse 2 Ventures, LLC (operator of Impactive.AI) and its affiliated companies (“Company,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our website and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us. 

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

STUDENT SUCCESS QUESTIONNAIRE

The Services allow you to complete our proprietary, detailed questionnaire (the “Student Success Questionnaire”) for us to prepare a personalized learning plan and summary report based on the answers you provide.

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you complete the Student Success Questionnaire, fill out a form, submit or post data through our Services, make a purchase, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, age, grade, school, email address, phone number, passwords, referral codes, social media handles, and any other information you choose to provide.

Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:

• Transactional Information: When you make a purchase, we collect information about the transaction, such as the purchase price, the date of the transaction, and the items you are purchasing from us.

• Usage Information: We collect information about your use of our Services.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we collect information about you from social media platforms and payment processors, including credit card and other personal information you provide to our payment processors when making a purchase.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about you based on your answers to the Student Success Questionnaire. 

USE OF INFORMATION

We use the information we collect to provide the Services to you.  We also use the information we collect to:

• Provide, maintain, and improve our products and services;

• Process transactions and send you related information, including confirmations, receipts, invoices, and customer experience surveys;

• Send you various updates and special offers relating to our services, products and merchandise and other marketing or promotional communications.

• Send you technical notices, security alerts, and support and administrative messages; 

• Respond to your comments and questions and provide customer service;

• Monitor and analyze trends, usage, and activities in connection with our Services; 

• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; 

• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Company and others;

• Debug to identify and repair errors in our Services; 

• Comply with our legal and financial obligations; and

• Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy: 

• We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, collecting questionnaire data, payment processing, fraud prevention, customer service, and marketing and advertising.

• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

• We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of the Company, our users, the public, or others.

• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

• We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

• Personal information is shared between and among Company and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.

• We share personal information with your consent or at your direction.

• We also share aggregated or de-identified information that cannot reasonably be used to identify you. 

COOKIES AND OTHER TRACKING MECHANISMS

We may automatically collect information about you through the use of common information-gathering tools, as well as new tracking technologies that develop as technology evolves. The tools that we or our service providers may use to track you include the following:

•  Cookies. A cookie is a small string of text that a website can send to your browser to help the website remember and customize your visit. For example, we use cookies to help us to tailor our Services to you, remember your orders, keep you logged into your account, and compile statistics about Services usage.  We may place cookies on your computer or device, and receive information stored in cookies, when you use our Services.  Below, you can find more information about the cookies that we use.  The cookies we use may include session cookies, which are deleted when you close your browser, and persistent cookies, which stay on your browser until they expire or you delete them.  We occasionally make changes, so the specific cookies we’re using may vary from what’s described below.

Cloudflare.  We use Cloudflare to help detect malicious visitors to our website.  For more information on the privacy practices of Cloudflare, please visit https://support.cloudflare.com/hc/en-us/articles/200170156-Understanding-the-Cloudflare-Cookies.

Google Analytics.  We use Google Analytics to track website traffic. Google Analytics is a web analytics service offered by Google. Google uses the data collected to track and monitor the use of our websites. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit: https://policies.google.com/privacy?hl=en. We also encourage you to review Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Company is headquartered in the United States, and we have operations and service providers in the United States. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Account Information

If you wish to delete your personal information, please email us at privacy@impactive.ai, but note we may retain certain information as required by law or for our legitimate business purposes.

Communications Preferences

You may opt out of receiving promotional emails from Company by following the instructions in those communications or by emailing us at privacy@impactive.ai. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

YOUR CALIFORNIA PRIVACY RIGHTS 

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. 

California Consumer Privacy Act

In the preceding 12 months, we have collected the following categories of personal information: identifiers, commercial information, internet or other electronic network activity, and inference data. 

For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. We launched the service in August 2024, since then, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Category of Personal Information

Categories of Recipients

Identifiers

Service providers 

Commercial Information

Service providers

Company does not sell your personal information.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested). 

• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services and communicate with you).

• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).

• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We store personal data associated with your account as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Subject Requests 

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email us at privacy@impactive.ai.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en 

For individuals in the UK: https://ico.org.uk/global/contact-us/ 

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

CONTACT US

If you have any questions about this Privacy Policy, please contact us at privacy@impactive.ai.