Wealth Education System (WES) Privacy Policy

This privacy policy (the “Privacy Policy”) governs your use of this web site, located at www.findwes.com, and all associated sites controlled or hosted by Wealth Education System (“WES” or “we” or “us”), or one of our subsidiaries or affiliates (collectively the “Site”). The Privacy Policy also applies to all mobile applications controlled or operated by us.

This Privacy Policy outlines the type of information that is collected through the Site and how that information is collected, used, disclosed and protected.

1. Your Consent to this Privacy Policy
By visiting the Site and/or using the services offered by WES, you agree to the terms of this Privacy Policy as they may be amended from time to time. This Privacy Policy is incorporated into the Wealth Education Solutions terms of use which govern your use of this Site. This Privacy Policy does not apply to third-party websites, products, or services even if they link to our Site, and you should consider the privacy practices of those third-parties carefully. If you disagree with the practices described in this policy, you should (a) take the necessary steps to remove cookies from your computer after leaving the Site, and (b) discontinue your use of services provided by WES through the Site.

2. Data We Collect
a. Personal Information. We may from time to time ask you for Personal Information, and we may collect certain information from your computer each time you visit our Site. “Personal Information” means data that identifies, or that could reasonable be used to identify, you as an individual and includes, for example, your name; street address; e-mail address; SMS or text message address; phone number; credit card and other payment information; and/or information that you choose to provide regarding your academic and extracurricular activities and interests that may identify you.

b. Other Data. We may collect information through a variety of other sources including the following:

i. Cookies and tracking technology data.
We may use “cookies” to keep, and sometimes track, information about you, and to create a personalized Web experience. Cookies are small data files that are stored on your computer’s hard drive. Cookies track where you travel on our Site and what you look at and purchase. By using this Site, you agree to our use of cookies.

ii. Clear GIFs.
We may use “clear GIFs” (a/k/a “Web beacons” or “pixel tags”) or similar technologies, on the Site and/or in our communications (e.g., in our HTML-based e-mails) which enable us to know whether you have visited a Web page or received or opened a message. This allows us to know the effectiveness of our marketing campaigns.

iii. Browser and device data.
We may collect data such as IP address, device type, operating system and internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Site you are using.

3. How Data is Used.
We may use data and Personal Information to

• provide you with our product and service offerings,
• process your orders and respond to your requests and inquiries, and manage your account and provide you customer service,
• maintain our internal records and otherwise manage our business,
• send you e-mail notices and offers and otherwise correspond with you, about products, services, and events that we think might interest you,
• perform research and analysis about your use of or interest in our products, services or products or services offered by others,
• develop and display content and advertising tailored to your interests on our site and other sites,
• enforce our terms and conditions,
• provide our advertisements to you when you visit other sites,
• perform functions as otherwise described to you at the time of collection, and

4. How Data is Disclosed.
In general, we will not disclose data and Personal Information without your consent. However, we may disclose data and Personal Information without your consent from time to time to certain third parties in the following circumstances:

a. WES Affiliates. We may share data and Personal Information with entities worldwide that we control, that control us or with which we are under common control.

b. Service Providers. We may share data and Personal Information with vendors and other third parties who help deliver our products and services, such as for example, website hosting service providers. These third parties are not authorized by us to use data and Personal Information in any way other than is necessary for the provision of such services.

c. Business Transfer. In the event that WES or all or a portion of its business, or one or more of its divisions, is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, data and Personal Information may be one of the transferred assets.

d. Legally Compelled Disclosures. We may disclose user information and data, including Personal Information, when compelled to do so by government authorities or otherwise as required or permitted by law, such as to respond to court orders and subpoenas. We also may disclose user information and data, including Personal Information, when we have reason to believe that someone is causing injury to or interfering with our rights or property, other customers or users of the Site, or anyone else that could be harmed by such activities.

5. Disclosures to Authorized Third Parties.
We may share data and Personal Information with third parties (“Authorized Third Parties”) in connection with WES’s services, provided that such disclosure is authorized by users of the Site.

6. Advertising
We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access the Site, based on data relating to your access to and use of the Site on any of your devices, as well as data received from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on your browser (including the use of pixel tags). They may also use these technologies, along with data they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop, and to make decisions about the advertisements you see.

In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technologies to identify the fact that you have visited our website or seen one of our advertisements, and we may provide that data to one or more third party advertising networks. The data we provide may include the time and date of your visit to our website, pages viewed, links clicked and other information that does not disclose your ‘real world’ identity. Those advertising networks may recognize the web beacon or cookie associated with your visit to our website when you visit other websites on which they serve advertising, and they may make decisions about the advertisements you see based on it. We may choose to work with Google AdWords, Doubleclick, AdRoll or other advertising networks. Each of these companies has its own privacy policy, which we encourage you to review.

7. Security
WES uses reasonable organizational, technical and administrative measures to protect data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.

8. Use of Service by Minors
The Site and the services provided by WES through the Site are not directed to individuals under the age of thirteen (18), and we request that such individuals not provide Personal Information through the Site.

9. Choice and Access
You have the right to “opt-in” and “opt-out” of certain of our uses of your Personal Information. For example, you may elect not to receive correspondence from us or have your Personal Information shared with other entities for their marketing purposes. You may make this request by sending an e-mail to us. In this e-mail, please say whether: (i) you would like to opt-out of receiving all e-mail promotional correspondence from WES in general or (ii) if you would like to opt-out of having your Personal Information shared with Authorized Third Parties or for marketing purposes or (iii) you would like to opt-out of receiving SMS or text messages. You may also opt-out of WES’s promotional e-mails by clicking on an opt-out link within the e-mail you receive.

Please understand that if you opt-out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.

10. Changes to this Privacy Policy
We will occasionally update this Privacy Policy. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this Privacy Policy. We recommend that you check our website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.