PRIVACY NOTICE OF
LOGICPREP LLC, WITH HEADQUARTERS IN 44 S BROADWAY, WHITE PLAINS, NY 10601

Last Updated: July 23, 2021

Logicprep LLC ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy. By accessing, using or registering in the site WWW.LOGICPREP.COM and related platforms provided by Company, including the client portal available at https://client.logicprep.com (collectively, the "Platform") and/or benefiting, directly and/or indirectly, from the products and services of Company ("Services"), ("Company"), you declare to be aware of and fully understand the terms of this privacy notice ("Privacy Notice").

For the purposes of this Privacy Notice, "Data Subject" is any natural person who accesses the Platform and/or relates directly or indirectly to the Company. The Company is the "Controller", being responsible for decisions regarding the processing of personal data executed directly and/or indirectly by the Company.

Among other individuals who may relate to the Company, the following persons are considered Data Subjects: prospects, students, parents or legal guardians of students and third parties.

If the Platform and/or the Company's Services are, in any way, used by children (under 16 years of age), the processing of the personal data of these children shall be authorized by the legal guardians, who shall be aware of and agree with the terms of this Privacy Notice. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at: contact@logicprep.com.

1. Platform and services

The Company provides educational advisory services, which, in summary, consist of: (i) college advising; (ii) test preparation and (iii) general educational support, especially by means of tutoring lessons.

The Platform is a website that allows the Data Subjects to register and book consultations and lessons prepared and conducted by the Company.

2. Data protection officer

The Company appoints the natural person qualified below for the position of "Data Protection Officer" or "DPO", who shall then be responsible for assisting and guiding Data Subjects in all matters relating to this Privacy Notice or the processing of personal data carried out by the Company, as well as act as a communication channel between the Data Subjects, the Company and the Brazilian Personal Data Protection Authority (ANPD).

For Brazil:

Name: Nina Feijo
E-mail: nina@logicprep.com
Phone: +55 11 94708-9149

For all other countries:

Name: Lindsay Howe
E-mail: lindsay@logicprep.com
Phone: +1 914-273-3280

3. data processing

In order to access and use the Platform and/or relate to the Company, the Data Subject will need to provide certain information to the Company, which are essential for the operation of the Platform and/or for the activities of the Company. Thus, the following personal data of the Data Subjects shall be collected and processed:

If the Data Subject is a prospect:

Name;
Telephone;
E-mail;
Address.

If the Data Subject is a client (student):

Name;
Telephone;
E-mail;
Address;
Photo;
Gender;
Nationality;
Family history;
Date of birth;
Resumé (with information selected exclusively by the Data Subject);
Passport (in specific cases);
Scholarity/Educational records;
Purchase history;
Behavioral profile;
Credit card;
Financial statement.

If the Data Subject is a legal representative of a child:

Name;
Telephone;
E-mail;
Address;
Profession;
Purchase history;
Behavioral profile;
Credit card;
Financial statement.

By accessing or using the Platform and/or the Services, you, the Data Subject, are aware – as a natural person and, when applicable, also as a representative of a child – of the processing of the aforementioned data, as well as declare that by providing data of third parties, personal or not, on the Platform (directly or through the insertion of documents containing such data) and/or to the Company, such provision is in accordance with the terms of the current legislation and does not violate the rights of third parties, being responsible for any and all claims or losses arising from the processing of personal data entered by you in the Platform (directly or by inserting documents containing such data) and/or provided by you, by any means, to the Company.

The Company may also collect personal data from third party databases, which may be public or not. The Company may combine this data with the existing information that the Company holds on the Data Subject or use it independently.

4. Purposes and Use of THE Data

This Privacy Notice lists below the main situations in which – and the purposes for which – the data of the Data Subjects, as well as the data of third parties in any way collected by the Company, are used:

Services: The Company will use personal data to: (a) book consultations or provide information about the Services; (b) send products (e.g. welcome pack, educational material etc.); (c) provide lessons and practice tests; (d) provide information about college applications and to sign up for official tests; (e) provide assistance with college applications, and; (f) provide customer services.

Use of the Platform: The Company will use personal data to: (a) facilitate the identification of the Data Subject on the Platform; (b) provide the necessary interactivity on the Platform, and; (c) operate and improve the Platform.

Payment: The Company will use personal data to charge for the Services.

Communication: The Company will use the personal data of the Data Subjects to contact the Data Subjects, as well as to send notices, text messages and/or reminders. The Company may send Data Subjects communications about the availability of the Platform, the solutions provided by the Company, the security of the Platform or other issues in any way related to the Platform, the Services and/or the Company, such as messages on how to use such Services and solutions or information about any updates available.

Advertising: The Company may use personal data to: (a) send marketing e-mails relating to the Platform, the Services or the Company and/or to companies of the same economic group of the Company; (b) display and/or send advertisements that are compatible with the Data Subject’s profile, and such advertisements may refer to the Platform, the Company and/or third parties. If the Data Subject is no longer interested in receiving advertisements, the Data Subject must contact the DPO, stating that he no longer wishes to receive advertising communications.

Activities of the Data Subjects on the Platform: The Company records the data of access and use of the Platform when the Data Subjects in any way access or use the Platform. The Platform uses the access information, cookies, device information and IP (Internet Protocol) addresses to identify the Data Subject or record the use they make of – or their activity on the – Platform.

Controller’s Database: The Company securely stores the personal data indicated in chapter 3 of this Privacy Notice, so that it can carry out its activities and offer its Services

Storage and backup: The Company backs up information relating to the Platform, the Services and the Company, which may include personal data.

5. Cookies AND SIMILAR TECHNOLOGIES

The Platform may use cookies or other technologies to help personalize the Data Subject's experience. Cookies are small text files stored in your computer's memory. A cookie contains information that can be read later by a server located in the domain that issued it. The information that cookies collect includes, amongst others, the date and time of the Data Subject's access, the Data Subject's browsing history, etc.

Cookies bring several benefits, since they allow the identification of previous Data Subjects when they return to the Platform, enabling the targeting of personalized content and/or similar services and products. Cookies also save time by making it unnecessary to enter the same information multiple times.

6. Duration of Data Processing

Personal data will be processed by the Company for as long as the purposes provided in this Privacy Notice remain applicable and/or there is a need to maintain them, for instance to comply with the legal time limits of storage, including those described in Law No. 12.965/14 (Brazil’s Internet Bill of Rights) and Decree No. 8,771/16, or to comply with other applicable legal or regulatory obligations.

Once the purpose or legal need is exhausted, the data will be deleted through safe disposal methods, or anonymization for purely statistical purposes.

7. Responsibilities and statements of the DATA SUBJECT

The Data Subject declares and acknowledges that, by making data, including personal data, available to third parties, on the Platform and/or to the Company (directly or by inserting or making available documents containing such data):

he previously informed the respective third parties and took all necessary measures to ensure that such third parties were aware of the processing of their personal data by the Company;

in the case of insertion of personal data of children, he previously took notice and obtained the consent of the respective legal guardians regarding the processing of such data by the Company;

in the case of insertion of sensitive personal data (racial or ethnic origin, religious conviction, political opinion, membership of a trade union or of an organization of religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when related to a natural person etc.), he previously took notice and obtained the consent of the respective Data Subject regarding the processing of said data by the Company; and

the information made available on the Platform, including any personal data, is complete, true and up to date, as well as it does not violate any third party rights or applicable legal norms.

If the aforementioned statements are not fully correct and/or the obligations assumed herein are not adequately fulfilled, the Data Subject is exclusively and fully liable for any damages caused to the Company or any third parties.

The Data Subject is responsible for the activities they execute on the Platform or for the information, including personal data, that they insert into the Platform (directly or by inserting documents containing such data) and/or make available to the Company.

In the event that the Company is demanded, at any time, for facts or acts of which the responsibility is attributed to the Data Subject, in accordance with the terms of this Privacy Notice, the Data Subject, as well as the child he represents, shall be jointly responsible and shall: (a) voluntarily intervene in the demand, requesting the immediate exclusion of the Company from the claim, (b) assume full and exclusive responsibility for the payment and/or the measures claimed, and (c) reimburse, in full, the Company for the costs and expenses incurred as a result of the demand. If such exclusion is not executed, the Data Subject, the child that the Data Subject represents, shall be responsible for the payment and full compliance with the decision or, if applicable, shall immediately reimburse the Company.

8. Data Sharing

The present Privacy Notice indicates below the situations in which the personal data of the Data Subject, as well as the personal data of third parties that in any way are inserted in the Platform by the Data Subject, will be shared by the Company:

Group companies: The Company may share information, including personal data of the Data Subject and third parties, with affiliates and companies of the same group whenever such sharing is important for the operation of the Platform, for the provision of the Services, for the performance of legal or regulatory obligations and/or are in the interest to the Data Subject.

Corporate operations: As a result of any corporate restructuring transactions, mergers, acquisitions, incorporations and the like, the Company may share or even transfer information, including personal data of the Data Subject and third parties, to individuals or legal entities that in any way are involved in the transaction.

Educational institutions: The Company may share information, including personal data of the Data Subjects and third parties, with educational institutions, namely colleges, that are of interest of the Date Subject, as indicated by them.

Partners and service providers: The Company may share information, including personal data of the Data Subject and third parties, with companies, organizations or individuals providing services on behalf of the Company to, for example, implement security measures, provide software availability and/or repositories necessary for the activities of the Company etc. These companies shall receive permission to obtain only the necessary information to adequately render their services and may be obligated to maintain confidentiality of the information.

Prevention of fraud and security: The Company may disclose or share information, including personal data of the Data Subjects and third parties, if they believe, in good faith, that the access, use, retention or disclosure of the information is reasonably necessary to (a) detect or prevent fraud, as well as resolve technical or security issues, and (b) ensure the security of the Platform, the Company, the Data Subjects and third parties. In these cases, data and information may be shared with third parties responsible for the investigation, including judicial organizations, authorities and information technology or information security companies.

Legal demands and investigations: The Company may disclose or share information, including personal data of the Data Subjects and third parties, with authorities and/or public agencies, regulatory agencies, legal authorities (e.g. regional police stations), regional authorities, consumer protection agencies, government and judicial organizations and/or lawyers in the following cases: (a) to comply with a judicial decision or governmental request; (b) to safeguard rights and prevent the Company's responsibilities; (c) to investigate, prevent or take action related to suspicious or actual illegal activities, or to cooperate with public agencies, and (d) investigate possible violations of the Company and/or third parties’ rights.

Compliance with legal or regulatory obligations: The Company may disclose or share information, including personal data of Data Subjects and third parties, to comply with legal or regulatory obligations or any other determination, before government and judicial agencies, including, but not limited to, Ministries and/or Government Secretariats, federal authorities, regulatory agencies and/or legal authorities (e.g. Federal Revenue Secretariat), consumer protection agencies, judicial agencies and others.

9. PROCESSING AGENTS

Any and all companies, public or private entities, authorities, organizations, agencies and/or persons who have access to the personal data of the Data Subjects and/or third parties, according to the situations provided for in the chapter "Data Sharing", shall assume the position of processing agent and shall be obligated, in accordance with the applicable legislation and/or the contracts executed with the Company, to adopt the best practices of security and governance with regard to the protection and processing of personal data that they had access to.

10. INFORMATION SECURITY

Information security is very important to the Company. The Company follows industry safety standards to help protect the information entered in the Platform or in any way obtained by the Company. However, there is no fully secure electronic storage method. IN THIS SENSE, ALTHOUGH WE STRIVE TO PROTECT THE INFORMATION PROCESSED BY THE COMPANY, WHICH INCLUDES PERSONAL DATA, WE ARE UNABLE GUARANTEE ABSOLUTE SECURITY.

The Company shall store the personal data of the Data Subjects and third parties in a secure environment, undertaking to adopt reasonable administrative and technical precautionary measures to prevent losses, abuses, alterations or unauthorized access related to this data.

11. Links

The Data Subject agrees not to hold the Company liable for losses, damages or other problems of any kind that may arise from the use of websites that contain links to the Platform or whose links that are available on the Platform, and is aware that such websites may not adopt appropriate practices with respect to the processing of personal data and privacy of the Data Subjects.

12. Control of your Data

The Company will provide means for the Data Subjects to access, correct, exclude or modify the data that were entered by them in the Platform and/or made available to the Company, to request the correction, exclusion or modification of the respective personal data. The Data Subjects’ options are listed below:

Confirmation of the existence of data processing: The Data Subjects may request confirmation regarding the existence of processing of their personal data.

Right to access your data: The Data Subjects may request a copy of the processed data, which will be made available in a readable and electronic format.

Data alteration or correction: The Data Subjects may request updates, alterations or corrections of their data in certain cases, especially if such data is incorrect or outdated.

Exclusion, blockage and/or anonymization of data: The Data Subjects may request the exclusion of their data from the Platform and the Company's repositories without the need to provide any justification, as well as request the exclusion, blockage and/or anonymization of said personal data.

Portability: The Data Subjects may request the portability of their data to another service or product provider.

Information on data sharing: The Data Subjects may request information about public and/or private entities with which the Company has shared their personal data.

Information on consent: The Data Subjects may request information on the possibility of not providing consent in specific situations and on the consequences of the non-provision of said consent.

Revocation of consent: In cases where the Data Subjects have given consent to the Company for the processing of their personal data, the Data Subjects may, at any time, revoke such consent.

Channels to require your rights: To require the rights listed above, the Data Subject must direct the requests to the Data Protection Officer. In the referred request, he shall include: (a) the qualification of the Data Subject (full name and e-mail); (b) the specification of the measure object of the Data Subject’s request in relation to his personal data, and; (c) if applicable, specify the data that is the object of the request. Unless otherwise established by the applicable law, within 15 days the Data Protection Officer will respond to the request of the Data Subject: (a) communicating the fulfillment of the request; (b) presenting justification, when it is not possible to comply with the request, or (c) estimating a new deadline for fulfilling the request and the justification for such extension.

There are situations in which the Company will need to maintain or will not be able to alter the personal data and, for this reason, will not be able to fully fulfill your requests, even if the aforementioned provisions are observed (e.g. when the maintenance of personal data is necessary to comply with legal obligations or court orders).

The Data Subject shall immediately inform the Company, through the Data Protection Officer, when the Company's cooperation is necessary to alter, update, supplement, correct or exclude personal data that has been made available on the Platform and/or to the Company. The Data Subject shall provide all the relevant information so that the Company may take the necessary provisions within a reasonable time.

13. COMPLAINTS

If a Data Subject believes that the Platform and/or the Company violates their rights and/or privacy, including with respect to the processing of personal data, they may communicate with the Company through the Data Protection Officer.

Nothing in this Privacy Notice is intended to exclude or limit any condition, warranty, right or liability that cannot be legally excluded or limited. Some jurisdictions do not allow the exclusion of certain warranties or conditions or the limitation or exclusion of civil liability. Consequently, only limitations that are permitted by law in your jurisdiction shall apply to you. IN CASES WHERE EXCLUSION OF LIABILITY IS NOT POSSIBLE, BUT THE LIMITATION OF LIABILITY IS LEGALLY APPLICABLE, THE COMPANY WILL NOT BE LIABLE FOR ANY LOST PROFITS, REVENUES, INFORMATION, OR DATA, OR CONSEQUENTIAL, SPECIAL, INDIRECT, EXEMPLARY, PUNITIVE, OR INCIDENTAL DAMAGES ARISING OUT OF OR RELATED TO THIS PRIVACY NOTICE AND THE COMPANY’S TOTAL LIABILITY ARISING OUT OF OR RELATING TO THIS PRIVACY NOTICE WILL NOT EXCEED $100 U.S.D (ONE HUNDRED U.S. DOLLARS).

14. Data Transfer ACROSS Borders

THE COMPANY PROCESSES DATA, INCLUDING PERSONAL DATA, IN BRAZIL AND IN OTHER COUNTRIES. IT IS POSSIBLE THAT SOME OF THE OTHER COUNTRIES IN QUESTION HAVE LESS PROTECTIVE LAWS REGARDING PRIVACY AND/OR PERSONAL DATA, OR DO NOT EVEN HAVE SPECIFIC REGULATION ON THE MATTER.

YOU ARE AWARE AND AGREE THAT YOUR PERSONAL DATA AND THE PERSONAL DATA OF THIRD PARTIES ENTERED IN THE PLATFORM OR MADE AVAILABLE TO THE COMPANY MAY TRANSIT BY - OR RECEIVE TREATMENT IN - OTHER COUNTRIES, AND, IN PARTICULAR, IN THE UNITED STATES.

15. ALTERATION, validity and FORCE of THE Clauses

Any waiver or alteration of the provisions of this Privacy Notice will only take effect if submitted in writing and signed by the legal representatives of the Company. If any provision of this Privacy Notice is voided or deemed unenforceable, the other provisions, whenever possible, shall remain valid and in force.

The Company reserves the right to alter the Privacy Notice, as well as any policy or document, at any moment and in its sole discretion.

The alteration will come into force at the moment of their publication on the Platform. The use of the Platform, the Services or the maintenance of a relationship with the Company after such publication shall constitute acknowledgement of the most recent version of the Privacy Notice. In this sense, we advise that the Data Subject reread the Privacy Notice frequently.

If there is any divergence between the content of this Privacy Notice and the content of any other document(s) signed between the Data Subject and the Company, the content of the other document(s) signed by the Data Subject shall always prevail.

16. Legislation, Disputes and CONTROVERSIES

Solely to the extent necessary to comply with applicable Brazilian law, if you are a consumer living in Brazil you acknowledge and agree that any dispute related to this Privacy Notice shall be submitted to the Courts of the District of São Paulo, State of São Paulo, Brazil, which shall prevail over any other, however privileged they may be or shall become, and will be judged exclusively in accordance with the laws of the Federative Republic of Brazil.

17. Questions and Clarifications

Questions, requests, complaints and comments about the Platform or the Privacy Notice shall be addressed to the Data Protection Officer.