ACEABLE PRIVACY NOTICE

This Privacy Notice describes how Aceable, Inc and its various brands, including PrepAgent (“we”, “us,” “our”) collects, uses and discloses information about individuals who use any of our websites (including https://www.prepagent.com/), applications, services, tools and features, or otherwise interact with us (collectively, the “Services”). For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Services, whether you are a customer, website visitor, job applicant, representative of a company with whom we do business, or another individual whose information we have collected pursuant to this Privacy Notice. Please note that the Services are designed for users in the United States only and are not intended for users located outside the United States.

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.

1. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

2. INFORMATION WE COLLECT

When you use or access the Services, we collect certain categories of information about you from a variety of sources.

Information You Provide to Us

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

• • Basic contact details, such as name, address, phone number, and email. We use this information to create and maintain your account and provide the Services, and to communicate with you (including to tell you about products or services that may be of interest to you).


• • Account information, such as username, password, and security questions that you select and the answers you provide. We use this information to provide the Services and to maintain and secure your account with us. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately.


• • Payment information, such as bank account, credit or debit card information, and billing address, which we collect using a third party payment processor and do not store or otherwise process ourselves. This information is used to process your payment and provide the Services.


• • Information required by licensing authorities, such as the last 4 or 5 digits of your social security number, your driver’s license number, state ID card or other identifiers, racial and ethnic origin and gender. We use this information to provide licensing authorities with the information needed to grant you your license after completion of your course.


• • Applicant details, such as information included in your resume or CV, references, and job history. We use applicant details to process your application for employment and to evaluate your candidacy.


• • Information provided when you choose to take a virtual exam, such as photographs and voice recordings, which is collected by a third-party exam proctor and which we do not store or otherwise process. Our third-party exam offeror uses this to verify your identity and otherwise provide exam-proctoring services.


• • Any other information you choose to include in communications with us, for example, when sending a message through the Services or interacting with our artificial intelligence-powered chat bots. We use this information to communicate with you.

Information We Collect Automatically

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies or other tracking technologies (“Tracking Technologies”). Usage Data includes:

• • Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.


• • Location information, such as approximate location.


• • Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data, keyboard strokes, interactions with marketing emails, and ad impressions.

We use Usage Data to tailor features and content to you, market more effectively to you, provide you with targeted offers or promotions, run analytics and better understand user interaction with the Services. For more information on how we use Tracking Technologies and your choices, see the section below, Cookies and Other Tracking Technologies.

Information Collected From Other Sources

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes:

• • Analytics data we receive from analytics providers such as Google Analytics, TikTok Pixel and Meta Pixel.


• • Information we receive from career websites, which we use to process your application for employment.


• • Information we receive from certain business partners regarding individuals who have completed courses, which we use to create and deliver course completion certificates.


• • Information we receive from third-party coupon providers. This information, which includes name, email, phone, voucher code, product and price, is used to verify your purchase and provide our Services to you.


• • Information we receive when you choose to link any social media platforms to your account or otherwise engage with us or others through our social media platforms, such as Facebook or X, which we use to maintain your account and login information and engage with you.

Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links.

In addition to the specific uses described above, we may use any of the above information to provide you with the Services and to maintain our business relationship, including by enhancing the safety and security of our Services (e.g., troubleshooting, data analysis, testing, system maintenance, and reporting), providing customer support, sending service and other non-marketing communications, monitoring and analyzing trends, conducting internal research and development, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting the Services, our rights, and the rights of our employees, users or other individuals.

Finally, we may deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (“deidentified information”) (or we may collect information that has already been deidentified/anonymized), and we may use such deidentified information for any purpose. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified/anonymized form and not attempt to re-identify the information, except solely for the purpose of determining whether our deidentification/anonymization process satisfies legal requirements.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including certain features and general functionality, to work incorrectly. If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

To opt out of tracking by Google Analytics, click here.

Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/.

4. DISCLOSURE OF YOUR INFORMATION

We may disclose your information to third parties for legitimate purposes subject to this Privacy Notice, including the following categories of third parties:

• • Company Group: Our affiliates or others within our corporate group.


• • Service Providers: Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, marketing communications, surveys, payment networks, and payment processing.


• • Marketing and Analytics Providers: Third parties for marketing and/or web analytics purposes.


• • Regulatory Bodies: State regulatory bodies who provide and maintain your licensure.


• • Other Third Parties: Third parties to whom you request or direct us to disclose information, such as through your use of social media widgets or login integration or when you request to send referral information through our broker matching program.


• • Advisors: Professional advisors, such as auditors, law firms, or accounting firms.


• • Business Transaction Parties: Third parties in connection with or anticipation of an asset sale, merger, or other business transaction, including in the context of a bankruptcy.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

5. SOCIAL FEATURES

Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third-party platforms, and from there “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Third Party Websites and Links.

6. THIRD PARTY WEBSITES AND LINKS

We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

7.CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

8. ATA SECURITY AND RETENTION

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, satisfy a state regulatory requirement, resolve a dispute, or enforce our contractual agreements.

9. CALIFORNIA RESIDENTS

This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).

Processing of Personal Information

In the preceding 12 months, we collected and (where indicated below) may have disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

Category	Categories of Recipients
Identifiers such as name, e-mail address, IP address	Company Group Service Provider Marketing and Analytics Providers Regulatory Bodies Other Third Parties
Personal information categories listed in the California Customer Records statute such as name, social security number*, address, telephone number, driver’s license* or state identification card number*	Company Group Service Provider Regulatory Bodies Other Third Parties
Characteristics of protected classifications under California or federal law such as race*, sex (including gender and gender identity*), and age	Company Group Service Provider Regulatory Bodies
Commercial information such as records of products or services purchased	Company Group Service Provider
Internet or other similar network activity such as information regarding your interaction with the Platform	Service Provider
Geolocation data such as IP address	Service Provider
Audio, electronic, visual or similar information such as photographs, video recordings and voice recordings	Service Provider
Professional or employment-related information such as title of profession, employer, professional background	Company Group Service Provider
Non-public education information collected by certain federally funded institutions such as education records	Company Group Service Provider
Government Identifiers* such as Social Security, driver’s license, or state identification cards or numbers	Company Group Service Provider Regulatory Bodies
Account access credentials* such as account log-in	Service Provider
Racial or ethnic origin*	Company Group Service Provider Regulatory Bodies

The specific business or commercial purposes for which we collect your personal information and the categories of sources from which we collect your personal information are described in the section above, Collection and Use Your Information. We only use and disclose sensitive personal information for the purposes specified in the CCPA. The criteria we use to determine how long to retain your personal information is described in the section above, Data Security and Retention.

We disclosed personal information over the preceding 12 months for the following business or commercial purposes:

• • to communicate with you, provide you with products and services, and market to you
• • to maintain and secure your account with us
• • to process your payment
• • to evaluate your candidacy and process your application for employment

Selling and/or Sharing of Personal Information

While we do not sell data in the traditional sense, we do engage in certain targeted advertising practices that may be considered “selling” or “sharing” under the CCPA (but we do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age). Specifically, in the preceding 12 months, we have disclosed the following categories of personal information about residents for cross-context behavioral advertising purposes:

Category	Categories of Recipients
Online Identifiers, IP address, email address	Marketing and Analytics Providers
Commercial Information	Marketing and Analytics Providers
Usage Data	Marketing and Analytics Providers

Your California Privacy Rights

As a California resident, you may have the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• • Right to Know. You have a right to request the following information about our collection, use and disclosure of your personal information:
  • ○ categories of personal information we have collected, disclosed for a business purpose, sold, or shared;
  
  
  • ○ categories of sources from which we collected personal information;
  
  
  • ○ the business or commercial purposes for collecting, selling, and/or sharing personal information;
  
  
  • ○ categories of third parties to whom the personal information was disclosed for a business purpose, sold, or shared; and
  
  
  • ○ specific pieces of personal information we have collected.


• • Right to Delete. You have a right to request that we delete personal information we maintain about you. This right may be limited by state requirements that we retain your information or other applicable exceptions.


• • Right to Correct. You have a right to request that we correct inaccurate personal information we maintain about you.


• • Right to Opt-Out of Sale or Sharing. You have a right to direct us not to sell or share your personal information. To exercise the right to opt out of selling or sharing, please click the “Do not sell or share my information” link at the bottom of any page on the website.

You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

In addition, California law permits residents to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for their direct marketing purposes. We may from time to time elect to share certain personal information about you with third parties for those third parties’ direct marketing purposes. Residents may, under certain circumstances, obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year. To make such a request, please contact us using the information listed below. Please note that we are only required to respond to one request per resident each year.

Notice of Financial Incentives

We offer certain loyalty benefits and rewards that may be considered financial incentives under the CCPA, such as exclusive offers and promotions via email. When you participate in these programs, we may ask you to provide us with contact information and identifiers such as your name and email address. Participation in these promotions is voluntary, and no purchase is required. While we cannot calculate the precise value of your information, our promotional programs generally reflect the value of the relationships that we have with the individuals who participate in them. You may opt out from our email communications at any time.

10. RESIDENTS OF OTHER U.S. STATES

If you are a California resident, please see the section above, California Residents, for information on your rights in relation to information that we have collected about you. If you are a resident of another U.S. state, depending on the state you live in, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law, including in the event you reside in a state that does not currently grant you these rights.

• • Right to Access. You may have a right to request that we confirm whether we process information about you and give you access to that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment.


• • Right to Delete. You may have a right to request that we delete information we maintain about you.


• • Right to Correct. You may have a right to request that we correct inaccurate information we maintain about you.


• • Right to Opt-out of Targeted Advertising. You may have a right to opt-out of the processing of your information for the purposes of targeted advertising (as all such terms and concepts are defined under applicable law). For information on how we process opt-out preference signals, see the section above, Cookies and Other Tracking Technologies.

You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth, before providing a substantive response to the request. Depending on your location, you may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

In addition, you may have the right to appeal our decision regarding a request related to these rights by contacting us using the information provided below. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfill your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

11. CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please email us at [email protected].