Privacy Policy

This is the Privacy Policy for Pocket Prep, Inc. and our affiliates and subsidiaries (collectively, “Pocket Prep“, “us“, or “we“). It is governed by and part of our Terms of Service. Any terms used in this Privacy Policy not defined herein are defined as provided in the Terms of Service. Any additional notices we may provide to you about our privacy practices will be considered to form part of this Privacy Policy.

This Privacy Policy describes how we treat information collected through our website pocketprep.com and the Pocket Prep mobile application (collectively, the “Services“). Please read this Privacy Policy carefully to understand our privacy practices. If you do not agree with this Privacy Policy, you must not access or use our Services.

If you have questions about this Privacy Policy or would like to make a complaint, please contact us online or by mail at Pocket Prep, 324 Blackwell Street, Suite 900, Durham, NC 27701.

1. Definition of “Personal Information”

As used in this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or household. To give you a sense of scope, below are examples of categories of information that are legally protected as Personal Information:

• Identifiers (e.g., name, email, telephone number, address, username);
• Sensitive Personal Information (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health data; contents of messages when we are not the recipient; in some cases, information about a known child);
• Legally protected information (e.g., race, citizenship, marital status, sex);
• Employment-related information (e.g., current or past employment);
• Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
• Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
• Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Internet or other similar activity (e.g., browsing history; content interactions); and
• Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.

The above list provides examples only. Pocket Prep limits its collection of Personal Information to what is necessary to provide the Services. We do not collect all the above categories of Personal Information.

Also, not all information about you is legally protected as Personal Information. Depending on where you live, publicly available information, aggregated information (meaning data summaries or reports with Personal Information removed), employment-related information, or anonymized information (that cannot be linked back to you as an individual) may not qualify as “Personal Information.”

2. Collection & Use of Personal Information

Pocket Prep only collects and processes your Personal Information: (i) with your consent as informed by this Privacy Policy and freely given at the time you provide the information; (ii) to fulfil our contractual obligations; (iii) with a legitimate interest; or (iv) as authorized or required by law.

The Personal Information we collect about you and the manner of collection depends on how you interact with the Services. Pocket Prep collects and processes Personal Information through the Services as a controller, or as a processor when processing the Personal Information on behalf of a Customer (as defined in the Terms of Service).  In all cases, Pocket Prep limits the collection, use, disclosure, and retention of Personal Information to what is necessary to accomplish the purposes described in this Privacy Policy, or notified at the time of collection, or as we collect email address, name, and in some cases phone number (optional) authorized by you directly or through the applicable Customer.

a. Categories and Sources of Personal Information

During the preceding 12 months, Pocket Prep has collected these categories of Personal Information:

• Identifiers
• Internet or other similar activity

Pocket Prep collects Personal Information from these sources:

• Your registration. You must register and create an account to use our mobile application and certain of our Services. The registration process will collect your name and email address.
• Your messages to us. If you contact Pocket Prep online, by email, or other means, we will collect your name, email address and other necessary information to respond to your inquiry. We collect this information with your consent, and we use it for the purposes stated at the time of collection, to provide you with Services, to provide technical or customer support, to communicate with you, or to market to you according to your stated preferences.
• Our newsletters and messages. If you sign up for our newsletter or other communications, we will use your contact information to send you those messages and materials. We may also send you promotional materials according to your communication preferences. You can unsubscribe from our mailing list at any time using the “UNSUBSCRIBE” link we include in marketing messages.
• Usage Data. When you visit the website or interact with the mobile application, we collect technical data about your device and session (e.g., IP address, browser type, generalized geolocation, language, session connection and disconnection time, bandwidth and referring URL) to provide you with technical support and to analyze and improve our Services. We may also use cookies to collect certain data, as described below in the Cookie Notice.
• No Payment Information. Pocket Prep does not collect or process payment information. If you make a purchase through our Services, you will be redirected to a secure third-party payment gateway such as Apple, Google Play, or Stripe. Payments made through payment gateways are subject to the payment gateway’s privacy policy, not ours. Pocket Prep is not responsible for the privacy policies of our third-party payment gateways as it relates to data like payment information that does not reside on our servers. Pocket Prep may keep small amounts of non-sensitive data, such as the last four numbers of a credit card, for limited administrative purposes.

b. Cookie Notice

We use cookies and similar tracking technologies for essential functions, features, analytics and advertising purposes. 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. Related technologies also used include beacons, tags, and scripts to collect and track information and to improve and analyze our Services. The cookies and related technologies used on our Services include:

• Essential cookies from Cloudflare (e.g., __cf_bm) for bot management and related purposes.
• Performance cookies from Cloudflare (e.g., _cfuvid) and LinkedIn.
• Analytics cookies from HubSpot, LinkedIn, and Google Analytics.
• Advertising cookies and pixels from LinkedIn (e.g., lidc, UserMatchHistory, bcookie, ar_debug, linkedin.com), Reddit, DoubleClick, Meta, and Google, as well as Pocket Prep’s first-party marketing attribution cookie.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent to your device. However, if you do not accept cookies, you may not be able to use some portions of our Services.

c. Other Uses of Personal Information

In addition to the specific uses described above, we might also use your Personal Information to (i) monitor your compliance with your agreements with us; (ii) protect your privacy and enforce this Privacy Policy; (iii) if we believe it is necessary, identify, contact, or bring legal action against persons or entities who may be causing injury to you, to us, or to others; (iv) comply with a law, regulation, legal process, or court order; or (v) fulfill any other purpose to which you consent. We will not collect additional categories of Personal Information or use already collected Personal Information for purposes that are materially different, unrelated, or not reasonably necessary or compatible with the original purpose without notice and consent as required by law.

d. Children’s Privacy

The Services are for adults, not children. DO NOT USE OUR SERVICES IF YOU ARE UNDER THE AGE OF 18. As part of our commitment to compliance with children’s privacy protections, we encourage you to contact us if you believe we might have collected any information online from a child so that we can delete it.

3. Data Retention

Pocket Prep’s policy is to retain Personal Information only for as long as necessary to accomplish the purposes stated at the time of collection or described in this Privacy Policy. We may also retain Personal Information for other purposes that are compatible with the original purpose of collection or as informed by our company retention policies. For example:

• Your registration data is retained as long as your account remains active or until you request deletion.
• Usage Data is retained for internal analysis purposes. Usage Data is generally retained for a shorter period, 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.
• Data collected through cookies may be retained for a few minutes or for several months, depending on the cookie’s purpose and functionality.

Pocket Prep reserves the right to also retain and use Personal Information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

4. Disclosures to Third Parties

Pocket Prep will only disclose your Personal Information with your permission, as described in this section, or as required by law. In the preceding 12 months, Pocket Prep has disclosed Personal Information we collected through the Services to third parties for one or more business purposes as detailed below. We will not disclose Personal Information to third parties except as described in this section or with your consent.
Personal Information may be disclosed to the following recipients:

• Our Sub-Processors. Third-party service providers that provide us with data hosting, payment processing, email management, analytics, or other services may have access to your Personal Information to perform their contractual obligations to us. The type of information that we disclose to a service provider depends on the scope of its services. Pocket Prep contractually prohibits these service providers from selling or sharing the Personal Information, and we require all service providers to maintain confidentiality standards and appropriate technical and organizational measures to ensure the security of your Personal Information. A list of our current service providers is available upon request.
• Our Customers. If you use our Services through a B2B Customer with which we have a contractual agreement, that Customer will have access to your registration information and data associated with your use of the Services.
• Cookie data recipients, subject to their respective privacy notices. See our Cookie Notice for details.
• Artificial Intelligence. Pocket Prep uses artificial intelligence to support the development and improvement of our Services. Any data used in artificial intelligence processes remains within our controlled environment and is handled in accordance with this Privacy Policy. We ensure that any artificial intelligence service providers we use do not use your Personal Information for training external models.
• Affiliates and Other Third Parties. Pocket Prep may disclose the Personal Information we collect to our business affiliates or subsidiaries. Their use and disclosure of your Personal Information will be subject to this Privacy Policy. Additionally, under some circumstances we may disclose Personal Information we collect as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
• Law enforcement, and other governmental agencies. In some rare cases, Pocket Prep may be required to disclose, and may disclose, Personal Information in response to lawful requests by public authorities. It is our policy in these cases to only disclose Personal Information when and to the extent required to comply with applicable law.
• Aggregated and Deidentified Information. Pocket Prep reserves the right to share aggregated, anonymized, or de-identified information about any individuals with nonaffiliated entities for marketing, advertising, research or other purposes, without restriction.

5. Your Privacy Controls

Pocket Prep gives you the ability to directly control the Personal Information we collect and hold about you through our Services:

• Your Login. You can update your information by logging into your account. If you need support to correct, update, or delete your Personal Information, please contact us. Pocket Prep customer support will make changes as permitted.
• Text Message Consent and Opt-Out. If you provide us with your wireless number, you consent to Pocket Prep sending you text messages for informational or authentication purposes. If you opt-in to our marketing texts, we will also use your wireless number to send you texts about offers, promotions, or ads. The number of texts that we send to you will be based on your circumstances and requests. You can unsubscribe from text messages by replying STOP or UNSUBSCRIBE to any of the text messages we send to you. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
• Marketing Emails. Depending on your communication preferences, we may also send you marketing emails. If you do not wish to receive emails from Pocket Prep, you can unsubscribe or change your preferences via the links provided in the emails or send a request to be removed from our email list. If you opt out of our marketing communications, we may still send you non-promotional communications.
• Device Settings. You can adjust your device settings to control how we automatically collect certain data.
• Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.
• Privacy Requests. Depending on where you reside, you may be entitled to additional controls over your Personal Information. Read more about privacy rights that may be available to you in Section 6 (Notice of Privacy Rights). If you wish to exercise your privacy rights beyond the methods described above, or if you want to express concerns, lodge a complaint, or request information, please submit a verifiable Privacy Request by email to [email protected].

Pocket Prep may only legally fulfill a Privacy Request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are 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.

We endeavor to respond to privacy requests in accordance with the requirements of the law applicable to your jurisdiction. If we do not fulfill your request within the legally required timeline, you can appeal our response by contacting [email protected].
If Pocket Prep collects or processes your Personal Information as a service provider to a Customer, we will relay your request to the Customer for further processing. We will cooperate with the Customer’s instructions to honor your requests and privacy choices.

6. Notice of Privacy Rights

In the United States, consumer privacy is governed by state laws providing general consumer privacy rights, as well as federal laws addressing specific industries or data uses. This section provides notices of consumer privacy rights available through the state laws of California, Colorado, Connecticut, Nevada, Utah, Virginia, and other states with similar requirements. If you reside in a state offering privacy protections (“Consumer”), you may be entitled to some or all these rights:

• Right to Correct. You have the right to request that we correct inaccurate Personal Information about you on our systems. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., you change address), please inform us and we will update our records.
• Right to Access. You may have the right to receive confirmation that we have collected Personal Information about you and copies of the requested pieces of Personal Information in a portable and readily usable format. We may be legally prohibited from disclosing certain pieces of Personal Information, and we may be limited in the number or frequency of requests we must fulfill.
• Right to Deletion. You have the right to request that we delete or dispose of your Personal Information processed on our systems, with certain exceptions. We may permanently delete, de-identify, or aggregate the Personal Information in response to a request for deletion. Please note that we may not be able to delete Personal Information that we collect or process in our role as a processor or service provider to a Customer. If you delete your Personal Information, it may be impossible for us to continue providing the Services to you.
• No Profiling. The Services do not use any form of automated processing of Personal Information to evaluate, analyze, or predict your performance, preferences, choices, or behavior.
• Limited Use and Disclosure of Sensitive Personal Information. You may have the right to opt out or limit our use of your sensitive Personal Information. In no case will we use or disclose any sensitive Personal Information for the purpose of inferring characteristics about you.
• Opt out of Selling or Sharing Personal Information. Some states entitle consumers to opt out of the sale or sharing of Personal Information or targeted advertising practices. We do not sell your Personal Information or share your Personal Information for cross-contextual behavioral advertising. However, certain cookies used on our website may disclose data that constitutes “sharing” Personal Information under some privacy laws. To the extent that any cookies we use transmit Personal Information to a third party, you can prevent this transmission by blocking non-essential cookies on your browser or device.
• Right to Disclosure. You may have the right to receive details about the collection and use of your Personal Information via the Services, such as: (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting, using, processing, sharing or selling that Personal Information, as applicable; (iv) the categories of third parties with whom we share that Personal Information; and (v) if we sold or shared your Personal Information under the California Consumer Privacy Act, two separate lists stating: (a) sales or sharing, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.
• Right to Nondiscrimination. We will not discriminate against you for exercising your privacy rights. For example, unless permitted by law, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.
• Health Data Rights. The Services are not designed to be used to collect health data. Please do not submit any health data through the Services. Some laws entitle consumers to certain details about health data collected about them, including (i) confirmation of whether the entity collects, shares, or sells the consumer’s health data and to access that data, including a list of all third parties and affiliates with whom the entity has shared or sold the health data and a method to contact those third parties, (ii) a method to withdraw consent related to use of health data, and (iii) the right to have their health data be deleted.
• Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.

To exercise your rights or ask questions, please contact us. In cases where your request must be submitted to the applicable Customer we will instruct you to do so.

7. Data Security

Pocket Prep is committed to safeguarding the Personal Information entrusted to us. We have implemented and maintained reasonable and appropriate security measures to help protect Personal Information in our possession from unauthorized access, processing, alteration, or disclosure. We use a combination of technical and organizational measures, procedures, and standards to govern Personal Information processing and safeguard the data in our possession. Our security measures are designed to meet our duty of care related to your Personal Information. Please note, however, that no transmission of data over the Internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.

You are encouraged to take steps to protect against unauthorized access to your account and device(s) by choosing a robust password that nobody else knows or can easily guess, keeping your password and links private, and signing off after using a shared device. Pocket Prep is not responsible for lost, stolen, or compromised passwords, or for unauthorized activity using your login credentials.

8. Services Offered in the United States

Pocket Prep is owned and operated in the United States, and we market our Services in the United States only. If you access the Services from outside the United States, please be aware that your Personal Information may be transferred to, processed, stored, and used in the United States or other jurisdictions. When your information is moved from your home country to another country, the laws and rules that protect your Personal Information in the country to which your information is transferred may be different from those of the country where you live. For example, if your information is in the United States, it may be accessed by government authorities under United States law. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this section.

9. Third Party Services

The Services may contain links to services owned or operated by third parties. Pocket Prep has no ability to control and is not responsible for the privacy or data collection, use, or disclosure practices of third-party services. You are encouraged to read the privacy statements of each service that collects your Personal Information.

10. Changes and Updates

Pocket Prep reserves the right to update this Privacy Policy from time to time. The date that this Privacy Policy was last updated is at the top of this page. Your continued use of the Services after we post updates is deemed to be your acceptance of the corresponding changes to our privacy practices.