CollegeCounsel

Privacy Policy

CollegeCounsel Platform operated by Skooly Pte Ltd

Last Updated: October 21, 2025

PRIVACY POLICY

CollegeCounsel Platform
Operated by Skooly Pte Ltd
Last Updated: October 21, 2025


INTRODUCTION

Skooly Pte Ltd (“Company,” “we,” “us,” or “our”) operates the CollegeCounsel platform at getcollegecounsel.com (the “Platform”). We are committed to protecting your privacy and personal information.

This Privacy Policy explains:

By using the Platform, you agree to the collection and use of information in accordance with this Privacy Policy.


1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

Account Registration Information:

Profile Information:

User Content:

Payment Information:

Communications with Us:

1.2 Information Collected Automatically

Device and Usage Information:

Cookies and Tracking Technologies:

We use cookies and similar technologies to collect information about your use of the Platform. See Section 2 for details.

Log Files:

Zoom Meeting Data:

1.3 Information from Third Parties

Identity Verification:

Payment Processing:

Referrals:

1.4 Information About Minors

For users aged 15-17, we collect the same information as adult users, but:

We do NOT knowingly collect information from children under 15. If we discover we have collected information from a child under 15, we will delete it immediately.


2. COOKIES AND TRACKING TECHNOLOGIES

2.1 What Are Cookies?

Cookies are small text files stored on your device that help websites remember information about your visit.

2.2 Types of Cookies We Use

Essential Cookies (Required for Platform Function):

These cookies are necessary for the Platform to function and cannot be disabled without affecting functionality.

Analytics Cookies (Requires Your Consent):

2.3 Managing Cookies

You can control cookies through:

  1. Our Cookie Consent Banner:

    • When you first visit, you’ll see a banner asking for consent
    • Choose “Accept All” or “Reject Non-Essential” or “Customize”
    • Change preferences anytime in Account Settings > Privacy > Cookie Preferences
  2. Browser Settings:

  3. Google Analytics Opt-Out:

Note: Disabling essential cookies will affect Platform functionality (you may not be able to log in or use certain features).

2.4 Do Not Track Signals

Currently, we do not respond to “Do Not Track” browser signals. However, you can control tracking through the methods described above.

2.5 Other Tracking Technologies

Local Storage: We use browser local storage to:

Unlike cookies, local storage data does not expire automatically and is not sent to our servers with every request.


3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

3.1 Provide and Improve the Platform

3.2 Analytics and Improvement

3.3 Safety and Security

3.4 Communication

3.6 AI and Machine Learning (Future - Phase 2)

Planned for future phases:

Important:


4. HOW WE SHARE YOUR INFORMATION

We do NOT sell your personal information to third parties. We share information only as described below:

4.1 With Other Users (As You Direct)

Students and Counselors:

Parents:

Schools:

4.2 With Service Providers

We share information with third-party service providers who help us operate the Platform:

Amazon Web Services (AWS) - Hosting and Infrastructure

Stripe - Payment Processing

Zoom Video Communications - Video Conferencing

Google Analytics - Analytics (with your consent)

Email Service Provider (e.g., SendGrid, AWS SES)

Customer Support Tools (e.g., Intercom, Zendesk - if implemented)

We may disclose information if required by law or in good faith belief that such action is necessary to:

4.4 Business Transfers

If we are involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on the Platform before your information is transferred and becomes subject to a different privacy policy.

We may share information for other purposes with your explicit consent.

4.6 Aggregated or De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you, such as:


5. DATA RETENTION

5.1 Active Accounts

We retain your information for as long as your account is active and as necessary to provide services.

5.2 Account Closure

Standard Deletion Timeline:

Inactive Student Accounts:

Parental Deletion Requests:

We may retain certain information longer when required by law or legitimate business purposes:

5.4 Counselor Content

When a Counselor closes their account:


6. YOUR PRIVACY RIGHTS

Your rights vary depending on your location. We honor the strongest rights applicable to all users globally.

6.1 Rights Available to All Users

Access: You can access your personal information anytime through your account settings.

Correction: You can update or correct your information in account settings. For information you cannot change yourself, contact dpo@getcollegecounsel.com.

Deletion: You can request deletion of your account and data through account settings or by emailing dpo@getcollegecounsel.com. We will process deletion within 15-30 days.

Data Portability: You can export your data in machine-readable format (JSON) through Account Settings > Privacy > Download My Data.

Opt-Out of Marketing: You can unsubscribe from marketing emails via the link in any marketing email or through account settings.

Cookie Control: You can manage cookie preferences through our cookie banner or account settings.

6.2 Additional Rights for EU/UK Users (GDPR)

If you are in the European Economic Area, United Kingdom, or Switzerland, you have additional rights:

Right to Object: Object to processing based on legitimate interests or for direct marketing.

Right to Restrict Processing: Request that we limit how we use your data in certain circumstances.

Right to Withdraw Consent: Where we rely on consent, you can withdraw it anytime (this does not affect prior lawful processing).

Right to Lodge a Complaint: You can file a complaint with your local data protection authority:

Legal Basis for Processing:

6.3 California Residents (CCPA/CPRA)

If you are a California resident, you have the right to:

Know: Request information about personal information we collected, used, disclosed, or sold in the past 12 months.

Delete: Request deletion of your personal information (subject to certain exceptions).

Opt-Out of Sale/Sharing: We do NOT sell personal information. However, Google Analytics may be considered “sharing” under CCPA. You can opt out via cookie settings.

Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

Shine the Light: You can request information about how we shared personal information with third parties for their marketing purposes (we don’t do this, but you can request confirmation).

To exercise these rights: Email privacy@getcollegecounsel.com or use the data export/deletion tools in your account settings.

6.4 Other Jurisdictions

Australia (Privacy Act): You have rights to access and correct your information. Contact dpo@getcollegecounsel.com.

Singapore (PDPA): You can access, correct, and withdraw consent for your personal data. Contact dpo@getcollegecounsel.com.

India (DPDP Act 2023): You have rights to access, correct, erase, and data portability. Parents can exercise rights on behalf of children under 18.

China (PIPL): You have rights to access, correct, delete, and data portability. For cross-border data transfers, we use Standard Contractual Clauses.

6.5 How to Exercise Your Rights

Self-Service (fastest):

Email Request:

For Parents of Minors:


7. INTERNATIONAL DATA TRANSFERS

7.1 Where We Store Data

Our primary servers are located in Singapore (AWS Asia Pacific region).

This means if you are located outside Singapore, your information will be transferred to and processed in Singapore.

7.2 EU Data Transfers

For users in the European Economic Area, UK, or Switzerland:

Transfer Mechanism: We use Standard Contractual Clauses (SCCs) approved by the European Commission to protect your data when transferred from the EU to Singapore.

Safeguards:

Your Rights: You can request a copy of the SCCs by emailing gdpr@getcollegecounsel.com.

7.3 Other Jurisdictions

We comply with applicable data transfer requirements in all jurisdictions where we operate, including cross-border transfer rules in China (PIPL), India (DPDP Act), and other countries.


8. DATA SECURITY

8.1 Security Measures

We implement industry-standard security measures to protect your information:

Encryption:

Access Controls:

Network Security:

Application Security:

Monitoring and Auditing:

File Security:

Third-Party Security:

8.2 Limitations

No system is 100% secure. Despite our efforts:

8.3 Your Security Responsibilities

You are responsible for:

8.4 Data Breach Notification

If we experience a data breach affecting your personal information:

Notifications will include:


9. CHILDREN’S PRIVACY

9.1 Age Restrictions

Consent Process:

  1. Student enters date of birth during registration
  2. If under 18, system requires parent/guardian email
  3. Parent receives email with:
    • Link to this Privacy Policy
    • Link to Terms of Service
    • Explanation of data collection
    • Consent verification link
  4. Parent clicks verification link to provide consent
  5. Account activated only after parental consent

Ongoing Parental Rights: Parents of users under 18 can:

Contact for Parents: parents@getcollegecounsel.com

9.3 Special Protections for Minors

For users under 18:

9.4 If We Learn a Child Under 15 is Using the Platform

If we discover that a child under 15 has provided personal information:

If you believe a child under 15 has provided information, please contact us immediately at privacy@getcollegecounsel.com.


10. EDUCATIONAL RECORDS AND FERPA

10.1 FERPA Overview

The Family Educational Rights and Privacy Act (FERPA) is a U.S. federal law protecting the privacy of student education records.

10.2 Our Role

For Schools Using the Platform:

For Independent Counselors:

10.3 How We Protect Educational Records

We protect educational records by:

10.4 Parents’ and Students’ Rights Under FERPA

For students 18+ or parents of students under 18:

To exercise FERPA rights: Contact your school’s administration (not CollegeCounsel directly). Schools control educational records; we merely provide the technology platform.

10.5 Student-Generated Content

Important distinction:


11. COOKIES AND ONLINE ADVERTISING

11.1 Our Advertising Practices

We do NOT:

We DO use Google Analytics (with your consent) to:

Google Analytics does NOT collect personally identifiable information.

The Platform may contain links to third-party websites (college websites, scholarship databases, etc.).

We are not responsible for the privacy practices of external sites. We encourage you to read their privacy policies before providing any information.

11.3 Social Media Features

If we integrate social media features (like sharing buttons), these features may:


12. CHANGES TO THIS PRIVACY POLICY

12.1 Right to Modify

We may update this Privacy Policy from time to time to reflect:

12.2 Notice of Changes

For material changes, we will notify you by:

Material changes take effect 30 days after notice (or as required by law).

12.3 Your Continued Use

Your continued use of the Platform after changes become effective constitutes acceptance of the updated Privacy Policy.

If you do not agree with changes, you should:

12.4 Prior Versions

We maintain prior versions of this Privacy Policy. You can request access to previous versions by contacting legal@getcollegecounsel.com.


13. CONTACT US

13.1 Privacy Questions

For questions about this Privacy Policy or our privacy practices:

Data Protection Officer:
Email: dpo@getcollegecounsel.com

General Privacy Inquiries:
Email: privacy@getcollegecounsel.com

Mail:
Skooly Pte Ltd
Attn: Data Protection Officer
[Your complete Singapore registered address]
Singapore

13.2 Data Subject Requests

To exercise your privacy rights (access, deletion, correction, etc.):

Email: dpo@getcollegecounsel.com or privacy@getcollegecounsel.com

Include in your request:

Response time: 30 days (may extend to 45-60 days for complex requests)

13.3 Parental Inquiries

For questions about minor accounts or to exercise parental rights:

Email: parents@getcollegecounsel.com

Include:

13.4 GDPR-Specific Inquiries (EU/UK)

Email: gdpr@getcollegecounsel.com

For:

13.5 FERPA-Specific Inquiries (US Schools)

Email: ferpa@getcollegecounsel.com

For:

13.6 Security Concerns

To report security vulnerabilities or data breaches:

Email: security@getcollegecounsel.com

For emergencies: Include “[URGENT]” in subject line


For users in the EU/UK/EEA, we process your data based on the following legal grounds:

PurposeLegal Basis
Account creation and platform servicesContract performance
Payment processingContract performance
Email notifications (transactional)Contract performance
Security and fraud preventionLegitimate interests
Analytics (Google Analytics)Consent (opt-in)
Marketing emailsConsent (opt-in)
Customer supportLegitimate interests
Legal complianceLegal obligation
AI features (future)Consent (opt-in)

Legitimate Interests: Where we rely on legitimate interests, we have assessed that our interests do not override your fundamental rights and freedoms. You have the right to object to processing based on legitimate interests.


15. YOUR CALIFORNIA PRIVACY RIGHTS

15.1 California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)

Categories of Personal Information We Collect:

Sources: Directly from you, automatically via cookies and analytics, from payment processors

Purposes: See Section 3 (How We Use Your Information)

Categories Shared: See Section 4 (How We Share Your Information)

We do NOT sell personal information.

We do NOT share personal information for cross-context behavioral advertising (except Google Analytics may qualify as “sharing” - you can opt out).

15.2 Shine the Light Law

California residents can request information about how we shared personal information with third parties for their direct marketing purposes in the prior calendar year.

We do not share information for third-party marketing purposes.

15.3 Minor Privacy (California)

California minors under 18 can request removal of content they posted. Contact privacy@getcollegecounsel.com to request removal.


16. AUTOMATED DECISION-MAKING

16.1 Current Practices

We do NOT currently use automated decision-making or profiling that produces legal effects or similarly significant effects on you.

16.2 Future AI Features (Phase 2)

When we introduce AI features (essay review, counselor matching):


17. DATA PROTECTION OFFICER

We have appointed a Data Protection Officer (DPO) to oversee our privacy program and ensure compliance with applicable laws.

Contact our DPO:
Email: dpo@getcollegecounsel.com
Mail: [Your Singapore address]

Our DPO is responsible for:


SUMMARY OF KEY POINTS

What we collect: Account info, profile data, user content (essays, files), usage data, cookies

How we use it: Provide services, improve Platform, ensure security, communicate with you

Who we share with: Service providers (AWS, Stripe, Zoom), law enforcement when required, other users as you direct

Your rights: Access, delete, correct, export, opt-out of marketing and analytics

Data location: Singapore (AWS)

Children: Age 15+ only; parental consent required for 15-17

Security: Encryption, access controls, monitoring

Retention: 15 days after account deletion; 1 year for inactive graduated students

Contact: dpo@getcollegecounsel.com


By using CollegeCounsel, you acknowledge that you have read and understood this Privacy Policy.


Skooly Pte Ltd
[Your complete Singapore registered address]
Singapore Company Registration No.: [Your UEN]

Last Updated: October 21, 2025
Effective Date: [Insert Date]
Version: 1.0

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