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Privacy Policy

 

At Socrates Invest LLC (“Socrates”) we take your privacy seriously. We have developed this Privacy Policy to clearly describe how we collect, use, and disclose your personal information as we provide our services and tools on or via this website, www.SocratesInvest.com, and its affiliated websites (“the Site”), collectively referred to herein as “Services.” The Services include the electronic ordering, fulfillment, and delivery of academic credentials and data, including without limitation, transcripts and related admissions documents, diplomas, test score reports, certificates and certifications (collectively, “Credentials”) and the electronic awarding of Credentials.

By accessing and using our Site or by clicking “I accept” prior to your registration on the Socrates Site, you consent to the collection, use and disclosure of your information and personal data by Socrates as described in this Privacy Policy.

What Information do we collect?

Automatic collection of information. Like many websites on the Internet, we automatically gather certain non-personally identifiable information and store it in log files. This information may include, for example, your IP address, browser type, and Internet connection speed. In addition, we may employ the use of “cookies” in certain areas of our Site. We use this information, which does not identify individual users through such users’ personally-identifiable information (PII) defined as data that we collect that could identify a single individual (including names, email addresses, postal addresses, and phone numbers), but does differentiate between users (as described in greater detail below) to analyze trends, to administer the site, to track users’ movements around the site, and to gather demographic information about our user base as a whole. We may link this automatically collected data to other information we collect about you.

Technologies such as cookies, beacons, tags and scripts are used by Socrates and our partners, affiliates, or service providers. These technologies are used in analyzing trends, administering the Site, tracking 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 third party companies on an individual as well as aggregated basis.

Cookies

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits the Site; and (2) third party cookies, which are served by service providers on the Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Type of cookie

Purpose

Essential Cookies

These cookies are essential to provide you with services available through the Socrates Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Site to remember choices you make when you use the Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit the Site.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to the Socrates Site and how users use our Site and Services. The information gathered may include the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information.  We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site. The information gathered does not identify any individual visitor. The information is aggregated and anonymous.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here.  You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.

Advertising or Marketing Cookies

These cookies are used to identify Site visitors that are either known or unknown to enhance the experience they have on our Site. These cookies allow us to provide content that is personalized to match visitors’ browsing or user history.

We use Marketo for marketing automation. You can find out more about their privacy policy and cookie policy here.  You can prevent the use of Marketo relating to your use of our Site by disabling this cookie here.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We do not currently respond to do not track signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

Information You Enter

We also collect information you choose to provide us through the Site or via email. For example, we obtain information when you create an account, complete a registration form or feedback form, contact us requesting information, purchase our Services, respond to a survey, contact a customer support representative, or opt-in to provide information to one or more of our affiliates through the Site.

This information may include information about you (for example, your name, email address, postal address, phone number), information about your institution (for example, a school’s name and address), and other information (for example, your graduation year and certain demographic information, when not associated with your personally-identifiable information). We may also collect other information not sourced from Credentials, including test scores (e.g. SAT, GRE, etc.), which may be collected if you choose to use certain admissions tools available through the Site.  If requested by your school in order to correctly identify your Credentials, we may request additional personal information from you, which may include the last four digits of your social security number.

When you use the Services offered on the Site, we may collect information regarding your use of the Services, including any communications made or transactions entered into by you.

You can choose not to provide us with certain information, but then you may not be able to successfully use the Services or take full advantage of the features of our Site.

If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

We collect feedback and correspondence from you, including information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Site, receive customer support, or otherwise correspond with us.

Information We Get from Others

We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners for purposes of the electronic ordering, fulfillment, and delivery of education credentials and data or other use related to the Services. We may add this to information we get from you in our Services.

We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide to us through our Services.

Changes to Your Personal Information

It is important that the personal information we hold about you is accurate and current.  Please let us know if your personal information changes during your relationship with us by updating your account information or emailing us at privacy@Socratesinvest.com.

Why do we collect your information and how is it used?

In general, we use information that we collect (i) to efficiently provide our Services, (ii) to improve your experience in using the Site and our Services, (iii) to aid in communication between Socrates and you, and (iv) to notify you of Services that we think may be of interest to you.

Personal or Institution Information

Any personal information that we collect is used to (i) facilitate the provision of Services that you may order and any related transactions and to further operate and improve our Services, (ii) personalize your account, (iii) maintain and customize the Services, (iv) develop new products and services, (v) allow communication between Socrates (its affiliates and service providers) and you, (vi) send administrative or service related emails, and marketing emails about upcoming products or services, which you may opt out of receiving as set forth below, (vii) provide support and maintenance for the Site and our Services, (viii) respond to your service-related requests, questions, and feedback, and (viii) as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Privacy.

Policy and Terms of Use; and (d) to protect our rights, privacy, safety or property and that of you or others, and (e) to protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

We will request your consent to use your personal information where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages.  If we request your consent to use your personal information, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us at support@socratesinvest.com

Anonymous Data

We may create anonymous data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by excluding information that makes the data personally identifiable to you.

Sensitive Personal Data

We do not collect and we ask that you do not send us or disclose any sensitive personal data (e.g. information related to racial or ethnic origin, political opinions, religious or other beliefs, health, biometrics, or criminal background) on or through the Services, with the exception of certain services on the Site where some users may opt in to providing ethnicity in order to participate in such service offering. If you send or disclose any sensitive personal data to us when you submit user generated content in our Services, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content in our Services.

Anonymous Information

We may use anonymous information in aggregate form to provide institutions with analytics on Credential exchange activity through the Services, including analysis to track where requests are coming from and going to, and benchmarking information. Additionally, we may use anonymous information in aggregate form to provide users with certain admissions-related analytics. These analytics rely solely on aggregated, anonymized data, and do not include any data from the Credentials we process.

We may use a third party to assist us in collecting and analyzing information as described below.

In addition, we use that anonymous data for our lawful business purposes.

How we share your information?

Our business hinges on security and the trust you place in us. We take great care to ensure that your personally identifiable information is only shared in the following limited circumstances:

  • Designated Institutions or Third Parties. When a student, academic institution, or other user uses our Services, we will access certain data, including personal information, and may transmit, fulfill, or otherwise disclose Credentials and related data to such other academic institutions or third parties as authorized by such user. The consent of a student-user’s parent may be required to submit a Credential request for non-postsecondary students under the age of 18. We will share certain information with the institutions from which we obtain your Credentials in order to fulfill your order.

  • Service providers. We may also use other companies and individuals to perform supporting functions on our behalf for the institutions that we work with or for the various Services offered through the Site, such as account billing and processing. They handle data only in compliance with the terms of this Privacy Policy, and will not be permitted to use the information collected from you for any purpose other than performing the support functions for Socrates.

  • Affiliates. We may disclose your personal information to our wholly owned subsidiaries, and any corporate affiliates or business partners, if any, and which are under common control with Socrates, for purposes consistent with this Privacy Policy.

  • Professional Advisors. We may disclose your personal information to professional advisors, such as lawyers, auditors, and insurers, where necessary in the course of the professional services they render to us.

  • Protection of rights. We may disclose your information if we believe that such action is appropriate to: (i) comply with law or any lawful requests and legal process, such as to respond to subpoenas or requests from government authorities, (ii) enforce the Terms of Use Agreement for the Site or this Privacy Policy, (iii) respond to claims that any information or content posted on our site or transmitted through the use of the Services violates the rights of any third party, or (iv) protect the rights, privacy, property, or personal safety of Socrates, its affiliates and employees, other Site users or others, or (v) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

  • Business transfers. Socrates may sell, transfer, or otherwise share your information to an acquirer, assignee or other successor entity in connection with the transfer or sale of all or substantially all of the equity, business, or assets of Socrates to which your information relates, or in connection with a sale, merger, bankruptcy, reorganization, change in control, or other similar transaction. Following such business transfer, this Privacy Policy may be assumed by the acquirer, assignee, or other successor entity and/or modified or replaced, subject to the modification terms (see below), and the acquirer, assignee, or other successor entity will be responsible for compliance under such policy.

 

International Data Transfer

We are headquartered in the United States and may have business partners or members in other countries, and your personal information may be transferred, in accordance with the terms of this Privacy Policy, to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

European Union users should read the important information provided here about transfer of personal information outside of the European Economic Area.

Storage of information

Once your service request has been fulfilled, Socrates does not retain such Credential, unless requested by the individual user, the sending institution, or the receiving institution, for the convenience of such user. For example, it is Socrates’s policy to comply with the sending institution’s preferences until the Credential is delivered. After the Credential is delivered, Socrates follows the receiver’s preferences regarding the retention and analysis of the transmitted Credential. If an individual user requests Socrates retain their Credentials on their behalf, Socrates will comply with such request and maintain the Credentials on behalf of such user in their personal account. Similarly, if an institution requests that Socrates store Credentials in the Socrates credential library, Socrates will comply with such request and maintain the Credentials on behalf of such institution in its credential library, subject to the applicable agreement between such institution and Socrates.

Your Choices

You can review, correct, update, or delete the information you provide Socrates by signing in to your account and accessing the Profile tab. Account holders may also contact us at privacy@Socratesinvest.com to accomplish the foregoing or if you have additional requests or questions. If you request that we delete your information, please note that your information may continue to reside in our backup systems.

From time to time, Socrates may provide you information on its various Services through email, telephone solicitations, and/or postal mail. You can opt-out of receiving these types of communications or access your personal information by clicking on an unsubscribe link at the bottom of each message or by contacting us at privacy@Socratesinvest.com. You may continue to receive service-related and other non-marketing messages.

If you have opted in to receive communication offered from third parties through Socrates, please contact each such party for information about their available opt-out procedures. We are unable to opt you out of third-party marketing programs.

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.

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account.  We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.

Security

We use industry-standard technology designed to protect your information and all transmissions made through our Site, and take reasonable measures to protect the confidentiality, security and integrity of personally identifiable information collected on our Site. Below are some of the highlights. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

The personal or institution identifiable information that you provide us is stored in secured facilities with restricted access, and protected by protocols and procedures designed to ensure the security of such information. In addition, all individuals who have access to such information are trained in the maintenance and security of such information, and we limit access of such information by our employees to the minimum information reasonably required in order to provide prompt, high quality Services.

When you enter sensitive information, such as your social security number, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it.  No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at support@socratesinvest.com.

If you create an account, you are responsible for maintaining the confidentiality of your account password and for activity that occurs under your account credentials.  Please email us at privacy@Socratesinvest.com if there are any unauthorized uses of your account or other breaches of security.

Third Party Services

Our Site includes links to other websites and services whose privacy practices may differ from those of Socrates. These links are not an endorsement, authorization, or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any site you visit.

Some of our partners may utilize framing techniques to serve content to and from webpages accessible through our Site while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to Socrates.

If you opt in to provide information to a third party whose services may be introduced by Socrates (e.g., through a site that is not owned or controlled by Socrates), please be aware that such collection of information is governed by the privacy statement of such third party.

Testimonials

We may display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.  If you wish to update or delete your testimonial, please contact us at privacy@Socratesinvest.com.

Social Media Widgets

Our Site includes social media features, such as the Facebook Like button and widgets, such as the ShareThis 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 such feature.

Children’s privacy

Our Site is a general audience website and no portion of the Site is directed to children under the age of 13. We do not collect personally identifiable information from any person we know is a child under the age of 13.

Should we be alerted that we have inadvertently collected personally identifiable information from a child under the age of 13, we will take steps to immediately delete it.

If you are a resident of California and under the age of 18, you may remove any content that you have posted to our Site. In the event you cannot remove the content, you may request for Socrates to remove the content by using sending an e-mail at privacy@socratesinvest.com. Please note that the removal of content or information from our Site does not ensure complete or comprehensive removal of the content or information posted on our Site.

Modifications

At Socrates, protecting your privacy is important to us. By accessing and using our Site, you consent to the collection, use and disclosure of information by Socrates as described in this Privacy Policy. We reserve the right to modify the Privacy Policy at any time. The “Last Updated” legend above indicates when this Privacy Policy was last modified. Although this Privacy Policy is subject to change from time to time, we will display a notice on the Site of any material change at least thirty (30) days prior to implementation of the revised Privacy Policy. We may also notify you by email in the event of such material change. If you have any questions concerning this policy please email us at privacy@Socratesinvest.com.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

 

Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at privacy@Socratesinvest.com

Privacy Notice for California Residents

Effective Date: 01 JANUARY 2020

This Privacy Notice for California Residents supplements the information contained in the Privacy Policy of Socrates Invest LLC (“Socrates”) and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

1) Information We Collect

From Consumers Directly. Our Services (as defined in the Privacy Policy) may collect information directly from consumers, which identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). This personal information may be collected directly from you on the Site (as defined in the Privacy Policy) or through the Services, or indirectly from you, for example by observing your actions in the Services or on the Site.

From Covered Businesses. Our Services may also collect such personal information from consumers indirectly from an educational institution, district, school, or other type of organization that may be a covered business under the CCPA. In such event, Socrates is deemed a service provider that processes personal information on behalf of such covered business for business purposes of electronic ordering, fulfillment, and delivery of academic credentials and data. Such processing activities are governed by the contract between Socrates and such covered business and the Privacy Policy of such covered business.

The Socrates Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

‌Personal information does not include:

  1. Publicly available information from government records.

  2. De-identified or aggregated consumer information.

  3. Information excluded from the scope of the CCPA.

 

2) Use of Personal Information; Business Purpose. We may use, or disclose the personal information we collect for one or more of the following business purposes, which includes without limitation to fulfill or meet the reason you provided the personal information to Socrates:  

 

  • to facilitate the provision of Services and fulfillment of orders that you may request, to create transactions that allow issuing institutions to process your requests for Services, and any related transactions;

  • to further operate and improve our Services; 

  • to personalize your account with Socrates; 

  • to maintain and customize the Services; 

  • to develop new products and services; 

  • to allow communication between Socrates and its affiliates and service providers and you; 

  • to send administrative or service related emails and marketing emails about upcoming products or services, which you may opt out of receiving; 

  • to provide support and maintenance for the Site and our Services; 

  • to respond to your service-related requests, questions, and feedback; 

  • as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Privacy Policy and contract with you; (d) to protect our rights, privacy, safety or property and that of you or others; and (e) to protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; 

  • as described to you when collecting your personal information or as otherwise set forth in the CCPA; or 

  • to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

Socrates may sell, transfer, or otherwise share your personal information to an acquirer, assignee, or other successor entity in connection with the transfer or sale of all or substantially all of the equity, business, or assets of Socrates to which your personal information relates or in connection with a sale, merger, bankruptcy, reorganization, change in control or similar transaction. Following such business transfer, this Privacy Notice and the Privacy Policy may be assumed by the acquirer, assignee, or other successor entity and/or modified or replaced, subject to the modification terms of the Privacy Policy and applicable law, and the acquirer, assignee, or other successor entity will be responsible for compliance under this Privacy Notice.

 

Socrates will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice by updating this Privacy Notice or otherwise.

3) Sharing Personal Information; Categories of Third Parties.

Socrates may disclose your personal information to a third party for a business purpose as outlined in this Privacy Notice and our Privacy Policy. Socrates does not sell your information except where you have opted-in to such Services whereby Socrates may disclose your personal information to a third party. You may opt out of such Services at any time as described in this Privacy Notice. We take great care to ensure that your personally identifiable information is only shared with the following categories of third parties:

  • Designated Institutions or Third Parties. When a student, academic institution, or other user uses our Services, we will access certain data, including personal information, and may transmit, fulfill, or otherwise disclose Credentials and related data to such other academic institutions or third parties as authorized by such user. The consent of a student-user’s parent may be required to submit a Credential request for non-postsecondary students under the age of 18. We will share certain information with the institutions from which we obtain your Credentials in order to fulfill your order.

  • Service providers. We may also use other companies and individuals to perform supporting functions on our behalf for the institutions and organizations that we work with or for the various Services offered through the Site, such as account billing and processing. They handle data only in compliance with the terms of this Privacy Policy, and will not be permitted to use the information collected from you for any purpose other than performing the support functions for Socrates.

  • Affiliates. We may disclose your personal information to our wholly owned subsidiaries, and any corporate affiliates or business partners, if any, and which are under common control with Socrates, for purposes consistent with this Privacy Policy.

  • Professional Advisors. We may disclose your personal information to professional advisors, such as lawyers, auditors, and insurers, where necessary in the course of the professional services they render to us. 

  • Protection of rights. We may disclose your information if we believe that such action is appropriate to: (i) comply with law or any lawful requests and legal process, such as to respond to subpoenas or requests from government authorities, (ii) enforce the Terms of Use Agreement for the Site or this Privacy Policy, (iii) respond to claims that any information or content posted on our site or transmitted through the use of the Services violates the rights of any third party, or (iv) protect the rights, privacy, property, or personal safety of Socrates, its affiliates and employees, other Site users or others, or (v) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

  • Business transfers. Socrates may sell, transfer, or otherwise share your information to an acquirer, assignee or other successor entity in connection with the transfer or sale of all or substantially all of the equity, business, or assets of Socrates to which your information relates, or in connection with a sale, merger, bankruptcy, reorganization, change in control, or other similar transaction. Following such business transfer, this Privacy Policy may be assumed by the acquirer, assignee, or other successor entity and/or modified or replaced, subject to the modification terms (see below), and the acquirer, assignee, or other successor entity will be responsible for compliance under such policy.

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

4) Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Socrates has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category J: Non-public education information.

Socrates discloses your personal information for a business purpose to the following categories of third parties:

  1. Designated Institutions or Third Parties.

  2. Service providers.

  3. Professional Advisors.

  4. Academic Research. 

  5. In connection with protection of rights. 

  6. In connection with business transfers.

5) Your Rights and Choices. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Socrates disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  1. The categories of personal information we collected about you.

  2. The categories of sources for the personal information we collected about you.

  3. Our business or commercial purpose for collecting or selling that personal information.

  4. The categories of third parties with whom we share that personal information.

  5. The specific pieces of personal information we collected about you (also called a data portability request).

  6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

  7. sales, identifying the personal information categories that each category of recipient purchased; and

  8. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

A verifiable consumer request is a request that originates from the Socrates registered account containing the personal information in question.

Deletion Request Rights

You have the right to request that Socrates delete all of your personal information that we have collected from you and retained on your behalf, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  3. Debug products to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  8. Comply with a legal obligation.

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by visiting www.Socratesinvest.com and accessing your account.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

  1. Provide your www.Socratesinvest.com account verification data to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account, we will deliver our written response to the email address associated with your account. If you do not have an account, we will deliver our written response to the email address associated with your verified consumer request.

Any disclosures we provide will cover at least the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us sending us an e-mail at privacy@socratesinvest.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Socrates does not disclose personal information to third parties for their direct marketing purposes. For more information, please send an email to privacy@Socratesinvest.com.

6) Changes to Our Privacy Notice

Socrates reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Site and/or the Socrates Services following the posting of changes constitutes your acceptance of such changes.

7) Contact Information

If you have any questions or comments about this notice, the ways in which Socrates collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (877) 855-1355
Website: www.Socratesinvest.com
Email: privacy@Socratesinvest.com

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, and/or email address.

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, address, telephone number.  Some personal information included in this category may overlap with other categories.

Yes

C. Protected classification characteristics under California or federal law.

Age (40 years or older),  or gender.

No

D. Commercial information.

Records of products or services purchased, obtained, or considered.

Yes

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

No

G. Geolocation data.

Physical location or movements.

No

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

I. Professional or employment-related information.

Current or past job history or performance evaluations.

No

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, or student disciplinary records.

No

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

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