PRIVACY POLICY

At torchlight.care (the "Site”), EnCompass Education Solutions, Inc., operator of the Site ("Torchlight", and also referred to in these terms as "we", "us", "our", or similar terms) understands that sharing your personal information online takes a great deal of trust. We take online privacy extremely seriously, and we strive to ensure the security and confidentiality of your personal information on the Site as detailed in this Privacy Policy. This Privacy Policy discusses, among other things, how data obtained during your visit to the Site may be collected and used. By visiting and using the Site, you affirm that you are of sufficient legal age to create and are fully able and competent to form a binding contract and that you agree to be bound by the terms of this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms of Service governing the use of this Site. We recommend that you read this Privacy Policy carefully. If you do not accept the terms of this Privacy Policy, you are directed to discontinue accessing or otherwise using the Site or any materials obtained from it. If you are dissatisfied with the Site, your only recourse is to disconnect from the Site and to refrain from visiting the Site in the future.

This Privacy Policy applies to the Site only. Since the Site contains links to other websites ("External Links") not protected under this Privacy Policy, once you click on an External Link, whether through an advertisement, content link, or any other means, you will no longer be on this Site and will no longer be protected under this Privacy Policy. Torchlight is not responsible for the privacy practices of the other sites to which we link, so we encourage you to carefully read and fully understand the privacy terms of every website you visit through an External Link contained on the Site. Additionally, if and only if you give your explicit and direct consent, Torchlight may share information among websites with which we partner, but we will never do so without your prior permission.

While you may use lot of the features of the Site without registering, many of the specific services, features and tools require registration. If you use the Site without registering, the only information we will collect will be Non-Personal Information (as defined below) such as through the use of Cookies and/or Advertising Trackers (as such terms are defined below). If you choose to register with the Site, we require you to submit some basic personal information, and you are responsible for ensuring the accuracy of the identifiable information you submit to Torchlight. Inaccurate information will affect the information you receive when using the Site as well as our ability to contact you as described in this Privacy Policy. If, for instance, your email address is not current, we may be completely unable to contact you.

We reserve the right to make non-material changes to this Privacy Policy that do affect your Personally Identifiable Information (as defined below), in which case Torchlight is under no obligation to notify you of such changes. We will inform you if we make a significant change to this Privacy Policy (i.e. a change that expands the permissible uses or disclosures of Personally Identifiable Information) by either sending a notice to the email address you provided to us or by placing a prominent notice on the Site. Your continued use of the Site following the provision of such notice will indicate your acceptance of these changes.

Torchlight is based in State of Massachusetts in the United States of America. Torchlight has designed and runs the Site to comply with US-based data protection rights laws. Privacy laws vary from country to country, and your own country’s privacy laws and regulations may be different than US law. If you are unsure whether this Privacy Policy is in conflict with applicable local rules, you should not submit your information. If you are located within the European Union, you should note that your information will be transferred to the United States of America, which is deemed by the European Union to have inadequate data protection. Individuals located in countries outside of the United States of America who submit personal information do thereby consent to the general use of such information as provided in this Privacy Policy and to its transfer to and/or storage in the United States of America.

COLLECTION OF NON-PERSONAL INFORMATION

Even if you do not register with the Site to become either a member or a Provider, we reserve the right to collect non-personally identifiable information about you ("Non-Personal Information"), which Non-Personal Information may be obtained by the use of Cookies and Advertising Trackers (as defined below) when you use the Site. Such Non-Personal Information generally is collected for all users, but does not personally identify you by name.

a. Cookies.

When you use the Site, we may use "Cookies", small packets of information and anonymous identification numbers that a website’s computer stores on your computer, in any one or more of the following ways: (1) to generate dynamically the content we display for you; (2) to monitor how many users open our emails; (3) to monitor how many users explore which pages of the Site; (4) to monitor how many users click on which advertisements and to generate dynamically advertisements that are most relevant to you; (5) to facilitate the login process; (6) to aid with navigation of the site; and (7) to serve as session timers. You can always choose not to receive a Cookie file by enabling your web browser to reject Cookies or to prompt you before accepting a Cookie. Please note that if you refuse to accept Cookies from the Site, you may be unable to access many of the features or specific tools offered on the Site, even though you generally still should be able to use the Site effectively and productively. In short, Cookies help us to deliver the content to you that is most relevant to your queries. We do not connect Non-Personal Information from Cookies to Personally Identifiable Information without your permission, and we do not use Cookies to collect or store personal information about you.

b. Advertising Trackers.

The information collected by Advertising Trackers can be used in any one or more of the following ways: (1) to allow us to determine accurately how many people are using the Site, as well as selected sponsors' and advertisers' websites, (2) to determine how many people open our emails, and (3) to determine the purposes for which these actions are being taken. Our Advertising Trackers are not used to track your activity outside of the Site’s domain or the domains of our sponsors and/or advertisers. We will never link Non-Personal Information from Advertising Trackers to Personally Identifiable Information without your permission.

c. Computer and Connection and Log Files.

We also reserve the right to determine what type of computer and web browser you are using, what website referred you to the Site, and what your connection speed is. This information is collected purely to enhance your experience on the Site. In addition, Torchlight may use IP addresses to analyze trends, administer the Site, track users’ movements and gather broad demographic information for aggregate use. We do not link you IP address to other Personally Identifiable Information about you.

PERSONAL INFORMATION

We may store any information you enter on the Site or provide or make available to us in any other way, whether by email, postal mail, phone, or any other means, including information that can personally identify you, such as your first and last name, telephone number, postal and email addresses, topics of interest, and any other information you may give us (collectively, "Personally Identifiable Information"). When you register as a member of the Site and/or when you update your member profile, we will have access to any Personally Identifiable Information or other information that you submit to us. We may use the information that you provide to respond to your questions, provide you the specific services you select or request, send you emails about the Site, and inform you of significant changes to this Privacy Policy. You can always decide not to provide information to us, but in order to register with the Site some information about you is required. At this time, we do not collect from registered members any financial information such as credit card information; if any External Link you visit asks you for such information, it is NOT affiliated with Torchlight or the Site, is not protected by this Privacy Policy, and is protected by the privacy policy of that website, if any, only.

a. Emails You Send to Torchlight

When you send us information by email, we may use that information to appropriately address your specific request or concerns, and may retain the content of your email messages together with your email address and our responses. For instance, if you send us a question regarding an educational program, childcare professional, therapist, or any other concern related to specialized educational resources, we may refer your question to appropriate professional for a suitable answer, although we make no guarantee that we will do so. By emailing us, you are explicitly giving us permission to use your Personally Identifiable Information at our discretion to attempt to find a response to your inquiry. Additionally, this Privacy Policy does not apply to content, business information, ideas, concepts, or inventions that you send to Torchlight by email. If you want to keep any such information private or proprietary, do not send such information in an email to Torchlight.

b. Composite Data.

Torchlight may combine, in a non-personally-identifiable format, any information that users of the Site provide to us in order to create Composite Data (as defined below) that may be disclosed or sold or otherwise provided to third parties. "Composite Data" does not contain any personal information that could be used to contact or identify you, but rather refers to information your computer automatically provides to us and which is not tied back to a specific individual, as well as aggregated or complied data such as the type of information that users of the Site may have requested in the past or the ways in which users use the Site. Examples include referral data (the websites you visited just before and just after our site), the pages viewed on the Site, time spent on the Site, and IP address, which may be used to create aggregate reports on user demographics and traffic patterns for advertisers, Providers and other partners, and for purposes of system administration. For example, Torchlight may use the information we gather from you and other users to create a composite profile of all the users who have selected to receive information about a certain type of educational service. These third parties may use this information to understand the needs of our users as an aggregate whole, in order to design appropriate programs and activities on their websites. Torchlight will not disclose your Personal Identifiable Information to any third party without your prior permission, except as otherwise permitted by this Privacy Policy.

HOW WE USE YOUR INFORMATION

By providing us with such personal information, you expressly grant Torchlight and all other persons or entities involved in the operations of the Site the right to transmit, monitor, retrieve, store and use such information in connection with the operation of the Site. In particular, Torchlight may use other information about you (1) to provide you with the products, services or procedures that you request; (2) to communicate with you in general; (3) to respond to your questions and comments; (4) to measure interest in and improve our products, services, and the Site generally; (5) to notify you about special offers and products, services or procedures that may be of interest to you; (6) to otherwise customize your experience with the Site; (7) to enforce our Terms of Service; and (8) as otherwise described to you at the point of collection. In addition, we may ask you to confirm your personal information when you contact us, as this will allow us to protect your confidentiality by verifying your identity.

If you have accessed the Site through a portal provided by Bright Horizons Children Centers LLC, or its affiliate ("Bright Horizons"), your use of the Site is subject to the terms and conditions of a license agreement between your employer or other third-party and Bright Horizons (the "Master License). In order to comply with the terms of the Master License and also to facilitate the registration and billing requirements of Torchlight and Bright Horizons, we may share both Composite Data and Non-Personal Information about you with Bright Horizons. In addition, if required under a Master License, we may share certain Composite Data with your employer or third-party provider. No Personally Identifiable Information about you will be shared with your employer or other third-party provider without your consent.

Except as set forth in this Privacy Policy or as specifically agreed to by you, in the Terms of Service, Torchlight will not disclose any information about you unless you specifically direct us to do so, either on the Site or otherwise. Torchlight may share information about you with one or more educational, childcare or special needs professional (each a "Provider"), according to the preference you select during the registration process, or your requests for services or information to Torchlight, whether via or through the Site or otherwise:

When you fill out and submit a form on the Site that asks for any personal information, submit only the information that you might want us to share with these third party Providers. We will process your information and filter it according to the specific procedure and/or destination(s) you specify, and use the resulting information to identify the Provider(s) who may be able to answer your questions or concerns. As described in more detail in the Terms of Service, Torchlight is not a medical professional and does not provide medical services of any type. Any information you disclose to these third-party Providers is not protected by our Terms of Service or by this Privacy Policy, and we do not endorse and we are not responsible for the privacy practices of these third party organizations.

Torchlight, through the Site, provides links to websites run by third parties that may pay us commissions based on sales of products, services or procedures generated through Site in order to maintain our costs. There may also be links to other third party organizations within the Site, in banner advertisements, or placed beside the names or logos of sponsors, advertisers or Providers. If you click on one of these links to a third-party website, any personal information you provide on those third party websites will not be governed by this Privacy Policy, and we strongly encourage you to review the privacy policies of those websites before submitting any personal information.

Torchlight also may share your information in the following situations:

  • a. Legal Compulsion: In response to legal proceedings, such as subpoenas, court orders, or search warrants; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
  • b. Investigations: When it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to defend or assert the rights, property, or safety of our organization, our customers, or others; and in connection with our Terms of Service. Should we be legally compelled to disclose your personal information to a third party, we will attempt to notify you about such an action unless doing so would violate the law or court order.
  • c. Corporate Transactions: In connection with a corporate transaction--such as a merger, divestiture, or asset sale--or in the unlikely event of bankruptcy.

HOW YOU CAN ACCESS YOUR INFORMATION

You can access your personal information by logging into your account on the Site using the username and password you provided during the registration process. You also can review, correct, change, add, delete or update information on your account page at any time. As discussed above, you can choose not to provide us with certain information beyond the information required to register and establish a member account, although such additional information may be helpful to connect to Providers and to take advantage of certain features on the Site. Even if you registered as a member of the Site, you will still be given the opportunity to unsubscribe from commercial messages in any such email we send. Please note that we reserve the right to send you other communications, including service announcements, administrative messages, and surveys relating to your account, without offering you the opportunity to opt out of receiving such communications.

If you have a complaint or problem, please contact us at support@torchlight.care. If you would like to remove your personal information entirely from the Site and our database, please email us accordingly. After receiving your email, we may require you to verify your identity before removing your information, such as by requiring you to reply to an email message sent to your then current email address, and also may require you to confirm your authority as the account owner by requiring you to respond with your account name and password. After we receive your confirmation and verify your authority with respect to the account, we will make every attempt to remove your personal information within one (1) week after which you will no longer be actively associated with the Site. Nonetheless, it may be impossible for us to remove every instance of information associated with you from all of our records, including log files, history digests or public forums or message boards, though the information may exist for our internal purposes only and will not be shared with other parties. In addition, you understand that, even after removal, copies of content provided by you may remain viewable in cached and archived pages or if other users have copied or stored such content.

If you chose to have us share your information with a third party Provider, you will have to contact them directly in order to remove your information from their databases. We do not maintain control over the databases of such third party organizations, and thus we cannot reasonably control the removal of your personal information from the databases of those organizations.

HOW WE PROTECT YOUR INFORMATION

We want you to feel confident about using the Site, so we are deeply committed to protecting the information we collect from our users. While no website can guarantee complete security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the personal information you provide to us. Only a small handful of authorized employees are permitted to access your personal information, and these individuals may do so solely for business functions as outlined in this Privacy Policy, our Terms of Service, or as we deem reasonably appropriate. In addition, we employ firewalls and intrusion detection systems to help prevent unauthorized parties from gaining access to your information by hacking into our system, and our server is located at a secure facility that cannot be accessed except by authorized personnel.

We will never ask you for credit card information or any other financial data, though the Providers and other third parties with which we partner may require such information from you.

There is always a risk that an unauthorized third party may gain access to your information by bypassing our security measures or by intercepting the transmission of your information over the Internet. For example, a spyware program that you may have inadvertently installed on your computer may be logging your keystrokes and sending the information to an unauthorized third party.

CHILDREN'S PRIVACY (COPPA)

The Site does not cater to children under the age of 13, and we are deeply committed to protecting the privacy of children. Should a child whom we know to be under the age of 13 send personal information to us, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her personal information. Neither Torchlight nor any of its affiliates nor services are designed or intended to attract children under the age of 13. Should a person under the age of 13 require the use of the Site, we encourage that child's parent or legal guardian to establish an account to be used by such parent or legal guardian on behalf of such minor, and it becomes that parent's or guardian’s responsibility to monitor the use of such an account. The parent or guardian is also responsible for maintaining the accuracy of any information so submitted. Furthermore, any information that Torchlight or any of our affiliates provides is directed at the parent or guardian, whom we hold responsible for interpreting and using that information. We take no responsibility for a child who knowingly falsifies his or her information in order to obtain information from us or from any of our Provider’s or other partner’s websites.

HOW TO CONTACT US

If you have questions about this Privacy Policy or any other concerns related to the Site, please email us at support@torchlight.care.