Privacy Notice
Last Updated: December 23, 2025
Overgrad, Inc. ("Overgrad," "we," "us," or "our") respects your privacy. This Privacy Notice ("Notice") describes the processing of Personal Information (defined below) that is provided, collected, or disclosed while providing our services to you, including on our website (www.overgrad.com) and our comprehensive college and career readiness platform (collectively, the "Platform"), as well as when you apply for a job with us. It also describes rights you may have under applicable laws. Please read this Notice carefully to understand our policies and practices regarding your Personal Information and how we will treat it.
If you provide us with Personal Information related to anyone other than yourself, please note that you are responsible for complying with all privacy and data protection laws prior to providing that information to Overgrad (including obtaining consent, if required).
Personal Information We Collect
We collect several categories of Personal Information from and about users of our Platform. "Personal Information" means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The categories of Personal Information we collect may include:
- Account and Education Information – When you set up your individual Overgrad account, we ask for certain Personal Information which may vary depending on the type of user you are. For example, if you are a student, we may ask for information such as your name, school, graduation year, birth date, phone number, and address. We may also collect your GPA, courses, test scores, and other information that will help connect you with colleges, universities, and/or employers. Similarly, if you are an educator or independent education consultant ("IEC"), we may ask you for your name, school or organization name, role, and/or certain other credentials.
- Usage Information – When you use our Platform, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs, domain names associated with your internet service provider, and any other information regarding your interaction with our Platform.
- Employment Information – If you apply for employment with us, we will collect Personal Information related to your potential employment, including your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
- Communication Information – We may collect Personal Information contained within your communications with us via email, chat functionality, telephone, or otherwise, and in certain cases we may use third-party service providers to do so. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees.
How We Collect Personal Information
- Directly From You – We collect Personal Information that you provide to us directly, for example, if you create an account, choose to contact us, submit a support ticket, request information from us, sign up to receive updates, or otherwise utilize our Platform.
- From Third Parties – We may collect Personal Information from third parties, including but not limited to school districts, universities, community-based organizations, employers, job training programs, business partners, advertising networks, social networks, data analytics providers, mobile device providers, Internet or mobile service providers, recruiters and job application portals, and background check providers.
- Through Online Tracking Technologies – We use cookies and similar technologies to collect Personal Information automatically as you navigate our Site. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.
How We Use Personal Information
To the extent permitted by applicable law, we use Personal Information:
- To provide and personalize our services, including college readiness, career readiness, academic planning, applications & financial aid, and counselor tools.
- For data collection and reporting, including providing real-time insights with dashboards and reports to enable users to track operational metrics and measure program impact.
- To optimize, improve, and maintain our Platform, including understanding how users interact with our Platform, gauging user interest in certain Platform functionality, and troubleshooting problems.
- For internal research and development, such as testing, verifying, and improving the quality of our Platform.
- For marketing and advertising, including using your information to send you messages, notices, newsletters, surveys, promotions, or event invitations about our own or third parties' goods and services that may be of interest to you. We also use Personal Information to conduct interest-based advertising as discussed in the Cookies and Other Tracking Technologies section below. You can manage your marketing and other communications preferences by logging into your Overgrad account. You can also unsubscribe from any marketing emails or text messages that we may send you by following the instructions included in the email or text correspondence.
- For communicating with you, such as responding to your questions and support requests, or notifying you of changes to our Platform.
- For legal, security, or safety reasons, such as protecting our and our users' safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
- As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business' assets, or another corporate transaction, including bankruptcy.
- To fulfill any other purpose for which you provide it, including purposes described when you provide the information or give your consent.
If you are applying for employment with us, we also use Personal Information to process your job application, to verify the information you have provided in your application, conduct interviews, perform background and reference checks, to communicate with you and answer your questions, to confirm your eligibility for employment, and improve our recruiting processes. We may also save your Personal Information for future employment opportunities with us.
How We Disclose Personal Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose your Personal Information with your consent or in the following circumstances:
- Other Users, School/Organization Administrators, and Third Parties – If you are a student user, we may disclose Personal Information with others as specified and/or directed by you, including counselors, school/organization administrators, universities, employers, community-based organizations, and job training programs. If you are an IEC, the information you provide when creating or editing your IEC profile (e.g. full name, biography, image, services offered, rate) will be accessible to other users of the Platform.
- Employees and Other Personnel – We may disclose Personal Information with our employees and personnel (such as contractors) who have a need to know the information for our business purposes.
- Service Providers – We disclose your Personal Information with the service providers that we use to support our business, including but not limited to, data analytics providers, website hosting providers, and other technology providers. If you are applying for a job with us, this may include service providers such as background check providers and human resource providers.
- Ad Tech Companies and Other Providers – We may share or make available limited Personal Information (such as a mobile device identifiers) with ad tech companies and other online service providers. When we share your Personal Information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.
- Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Overgrad, its employees and users, or the public against harm.
- Merger or Change of Control – We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you notice prior to such disclosure.
- Other – We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Cookies and Other Tracking Technologies
We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Site. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Site, to enhance your experience through personalization, and to help us better understand the features of our Site that you and other users are most interested in.
Platform Service Features
We may use third-party providers to enable certain customer interaction opportunities and other service capabilities. Examples include, but are not limited to, chat-based customer support. We use a Live Chat feature powered by a third party, and which may utilize artificial intelligence, to enable live customer service and technical support via our Site. When you engage in the chat enabled by this service provider, you may be interacting with an automated and artificial system, not a human representative. Additionally, to provide customer service and technical support, we will automatically collect and share certain information (such as personal identifiers, usage information, and message content) with the supporting vendor. Any Personal Information disclosed with that third party via this interactive tool will be handled in accordance with the applicable third party's privacy policy.
Website Analytics
We use analytics services that use cookies and other technologies that collect your Personal Information, to assist us with analyzing our Platform traffic and site usage to optimize, maintain, and secure our Site and inform subsequent business decisions (including, e.g., advertising). These include, but are not limited to, Google Analytics. To learn more about how Google uses data, visit Google's Privacy Policy and Google's page on "How Google uses data from sites or apps that use our services." You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools.
Interest-Based Advertising
We may also allow or enable third parties to collect Personal Information to provide their interest-based advertising on behalf of our products and services, or their own. Interest-based advertising occurs when advertisements are shown to you based on information collected from your online interactions over time and across multiple websites, devices, or online services that you visit or use. Some companies may engage in cross-context behavioral advertising to predict your preferences and show you advertisements that are most likely to be of interest or relevant to you.
We do not control these third parties' collection or use of your information for these purposes, or the opt-out options they may individually offer you via their terms, conditions, and privacy policies. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Selling Personal Information
While we do not sell Personal Information in exchange for monetary consideration, we do disclose Personal Information for other benefits that could be deemed a "sale" under various data protection laws because it is sometimes broadly defined to include activities such as the delivery of interest-based advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.
Cookie Choices
To manage your preferences with respect to these technologies, you can:
- Change your cookie preferences by customizing your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Site may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.
- Block the collection and use of your information by online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the opt out pages of the self-regulatory programs of which those companies are members: National Advertising Initiative and Digital Advertising Alliance. Please note that even if you opt out of interest-based advertising, you may still see "contextual" ads which are based on the context of what you are looking at on the websites and pages you visit.
- Review and execute any provider-specific instructions to customize your preferences or opt-out of certain processing, including interest-based advertising, by third-party service providers. For example, to opt-out of this type of advertising by Google, customize your ad preferences, or limit Google's collection or use of your data, visit Google's Safety Center and Google's Ad Settings and follow Google's personalized ad opt-out instructions.
How Long We Keep Your Personal Information
We retain your Personal Information for as long as needed: (i) to provide our Platform and services to you; (ii) fulfill the purposes outlined in this Notice; and (iii) to comply with our legal obligations, resolve disputes, and enforce any agreements. Criteria we will use to determine how long to retain your Personal Information include the nature and length of our relationship with you; our legal rights, obligations, and retention requirements; and if we have an ongoing purpose for retaining your Personal Information, such as communicating with you about ongoing or prospective services.
Links to Third-Party Websites
We are not responsible for the practices employed by any websites or services linked to or from our Platform, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be handled in accordance with the applicable third party's privacy policy.
We offer links to social media platforms like LinkedIn that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the terms of use and privacy policies for those platforms.
We may also integrate with other websites to provide enhanced services, technological capabilities, or resources for you. These plug-in services and capabilities are governed by the terms, conditions, and policies of the underlying companies. For example, we give you the option to login to the Platform via third-party services like Google, Clever, ClassLink, and LinkedIn. If you choose to leverage this option to link your accounts, we will receive information associated with your account (such as your name and profile information) from that third-party service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service. We recommend reviewing the service's privacy policy beforehand and managing your privacy settings on an ongoing basis.
International Use
If you are visiting our Site from outside of the United States, please note that our Site is hosted in the United States. Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Notice.
How We Protect Personal Information
We have implemented commercially reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.
Exercising Your Privacy Rights
Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:
- Access – The right to request access to and obtain a copy of any Personal Information we may have about you.
- Deletion – The right to delete your Personal Information that we have collected or obtained, subject to certain exceptions.
- Correction – The right to request that we correct any inaccuracies in your Personal Information, subject to certain exceptions.
- Opt Out of Certain Processing – The right to: (a) opt out of the processing of your Personal Information for purposes of targeted or cross-context behavioral advertising, (b) opt out of the sale of your Personal Information, and (c) limit the use of your sensitive Personal Information (if applicable). We do not collect or process sensitive Personal Information outside of purposes permitted by law, so we do not offer the option to limit its use.
- Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information.
- Automated Decision-Making – The right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). We do not profile you or other individuals in a manner that would result in legal or similarly significant effects, or engage in automated decision-making, so we do not offer an opt out of such activity.
- Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.
To exercise any of the privacy rights afforded to you under applicable data protection laws, please e-mail us at support@overgrad.com. Please note that you may access or update your account information at any time by signing into the Platform.
You may also exercise your opt out rights by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). We honor Opt-Out Preference Signals, including GPC. If you choose to use an Opt-Out Preference Signal, you will need to turn it on for each supported browser or browser extension you use.
You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Notice. However, should you withdraw your consent or choose not to provide certain Personal Information, we may be unable to provide some, or all, of our Services to you.
Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. We must verify your identity before fulfilling your requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a 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 may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.
Children's Privacy
We do not knowingly collect or solicit any Personal Information from children, as defined under applicable law, without verified written parental consent, and we have no actual knowledge of selling such Personal Information of minors under 16 years of age. If we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you believe we might have any information from or about a child, please contact us at support@overgrad.com.
California Residents
This section provides additional information regarding Overgrad's practices pursuant to the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act ("CCPA"), where "Personal Information" has the definition set forth in the CCPA.
Please see the below chart for detailed information about the categories of Personal Information we have collected from California residents during the twelve months preceding the date on which this Notice was last updated and the categories of third parties to whom we Sell or Share Personal Information (as those terms are defined in the CCPA). For each category of Personal Information set forth in the chart below, the categories of third parties to whom we disclose it for a business or commercial purpose are set forth in the How We Disclose Personal Information section above.
| Personal Information Category (Cal. Civ. Code § 1798.140) | Categories of Third Parties to Whom We Sell or Share Personal Information |
|---|---|
| Personal identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. | Third-party marketers and other third parties that set cookies and other online tracking technologies on our Platform. |
| California Customer Records Personal Information (Cal. Civ. Code § 1798.80(e)), including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, etc. | We do not Sell or Share this category of Personal Information. |
| Characteristics of protected classifications under California or federal law. This may include age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion. | We do not Sell or Share this category of Personal Information. |
| Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement. | Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Platform. |
| Geolocation data, such as your IP address. | Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Platform. |
| Sensory data including audio, electronic, visual, thermal, olfactory, or similar information. | We do not Sell or Share this category of Personal Information. |
| Professional or employment-related information. | Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Platform. |
| Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99) | We do not Sell or Share this category of Personal Information. |
| Inferences drawn from any of the information categories to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | We do not Sell or Share this category of Personal Information. |
| Sensitive Personal Information as set forth in Cal. Civ. Code § 1798.140, including racial or ethnic origin and account access credentials (like usernames or account numbers combined with password or other security/access code to access an account). | We do not Sell or Share this category of Personal Information. |
California Shine the Light – Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties' direct marketing purposes, if any. To make such a request, please contact us at support@overgrad.com. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
Changes to this Notice
Please note that we may modify or update this Notice from time to time, so please review it periodically. If we make material changes to how we treat Personal Information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Notice will apply immediately upon posting to our Platform. You are responsible for periodically visiting our Platform and this Notice to check for any changes.
Contact Us
If you have any questions about our practices or this Notice, please contact us at support@overgrad.com.