Privacy Policy

Last modified: November 26, 2025

Introduction

TruLeague Incorporated (“TruLeague” or "Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.truleague.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy, below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. Please see our “Retention of Your Information” section regarding our data retention policies. If you believe we might have any information from or about a child under 13, please contact us at: info@truleague.com. 

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.
• From communications that may be monitored by an institution's staff or by TruLeague for analytics purposes.

Information You Provide to Us. 

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information, below.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TruLeague Incorporated 's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TruLeague about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TruLeague, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

"We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement."

Retention of Your Information

• We will preserve personal data for as long as is necessary in order to provide you with the ability to use our website, address issues or concerns that may arise, or otherwise as is required by law or any relevant regulatory body. Some personal data may need to be retained for longer to ensure that we can comply with applicable laws and internal compliance procedures, including, for example, retaining your email address for opt out preferences. We restrict access to your personal data to only those persons who need to use it for the relevant purposes. Our retention periods are based on business needs and any information that is no longer needed is either anonymized or securely deleted.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by logging into the Website and adjusting your user preferences in your account profile or by sending us an email stating your request to info@truleague.com.
• Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties' products or services, you can opt out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@truleague.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@truleague.com.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: info@truleague.com.

Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information under applicable data protection laws, including the General Data Protection Regulation (GDPR) and similar laws. These rights may include:

• Right to Access: You have the right to request a copy of the personal information we hold about you.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal information.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal information when it is no longer necessary for the purposes for which it was collected or when you withdraw consent.
• Right to Restrict Processing: You may ask us to restrict the processing of your personal information in certain circumstances.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Object: You may object to the processing of your personal information, particularly where we rely on legitimate interests as our lawful basis.
• Right to Withdraw Consent: Where we rely on consent for processing your data, you may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that your rights under data protection laws have been violated. For EU residents, this may be with the supervisory authority in your country of residence, or you may contact our appointed EU representative using the details below.

To exercise any of these rights, please contact us at support@truleague.com.

We may ask you to verify your identity before responding to such requests.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the CCPA privacy notice for California Residents.

California's "shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@truleague.com or write us at: 245 Walnut Street, Unit E203, Newton, Massachusetts 02460.

Family Educational Rights and Privacy Act (FERPA)

This section applies only where TruLeague provides services to U.S. educational agencies or institutions (“Educational Institutions”) that are subject to the Family Educational Rights and Privacy Act (“FERPA”) and TruLeague receives, accesses, or processes “education records” on their behalf. In those cases, TruLeague acts as a “school official” with a legitimate educational interest under FERPA and processes education records solely for and at the direction of the Educational Institution.

Nothing in this section is intended to limit the rights of parents or eligible students under FERPA or to expand TruLeague’s role beyond that of a service provider to Educational Institutions.

Definitions Under FERPA

For purposes of this section:

• “Education Records” means records that are:
• Directly related to a student; and
• Maintained by an Educational Institution, or by a party acting for the Educational Institution, including records TruLeague maintains or processes on its behalf.
• “Personally Identifiable Information from Education Records” or “FERPA PII” includes, but is not limited to:

• Prospective Students: essential data – first name, last name, email address, encrypted password, country; additional data – the degree subject/level of interest (undergraduate/postgraduate), phone number, whether they have already applied to the Institution, and chat conversations and interactions with Ambassadors;
• Ambassadors: first name, last name, photo, phone number, email address, encrypted password, country/city/location, languages spoken, academic history (and previous high school; degree/university degree; degree level (undergraduate/postgraduate)); university year (1st, 2nd etc.), an ‘about me’ free text selection and chat conversations and interactions with Prospective Students; and
• Institution Staff: first name, last name, email address, encrypted password.

• “Parent” means a natural parent, guardian, or other individual acting as a parent in the absence of a parent.
• “Eligible Student” means a student who has reached 18 years of age or is attending a postsecondary institution, at which point FERPA rights transfer from the parent to the student.
• “School Official” includes TruLeague and its employees, contractors, consultants, service providers, and agents, to the extent that they:
• Perform services or functions on behalf of an Educational Institution that the institution would otherwise use its own employees to perform; and
• Are under the direct control of the Educational Institution with respect to the use and maintenance of education records.
• “Legitimate Educational Interest” exists when a School Official needs to access FERPA PII in order to fulfill their professional responsibilities for the Educational Institution (for example, to operate, maintain, support, secure, or improve the TruLeague platform and related services provided to the institution).

Parent and Eligible Student Rights

When TruLeague processes education records on behalf of an Educational Institution, the Educational Institution remains responsible for fulfilling FERPA rights. TruLeague will support the Educational Institution in honoring these rights, which typically include:

1. Right to Inspect and Review Education Records
   Parents and eligible students have the right to inspect and review the student’s education records maintained by the Educational Institution. Requests to access education records should be submitted directly to the Educational Institution, in accordance with its policies and procedures. Upon instruction from the Educational Institution, TruLeague will provide access to, or copies of, education records in TruLeague’s possession that are necessary for the institution to respond to such requests.
2. Right to Request Amendment of Education Records
   Parents and eligible students have the right to request that the Educational Institution correct education records they believe are inaccurate, misleading, or otherwise in violation of the student’s privacy rights. Requests to amend records should be directed to the Educational Institution. If the Educational Institution determines that amendment is appropriate and instructs TruLeague to correct, supplement, or delete data held within TruLeague systems, TruLeague will implement those changes in accordance with the institution’s instructions and applicable law.
3. Right to Provide Consent to Certain Disclosures
   Except where FERPA permits disclosure without consent, parents and eligible students generally have the right to provide written consent before a school discloses FERPA PII from education records. TruLeague does not make independent disclosure decisions for education records; rather, TruLeague processes and discloses FERPA PII only as directed by the Educational Institution and consistent with FERPA’s requirements and exceptions.
4. Right to File a FERPA Complaint
   Parents and eligible students have the right to file a complaint with the U.S. Department of Education concerning alleged failures by an Educational Institution to comply with FERPA. Contact details are provided in the “FERPA Complaint Contact Information” section below.

Disclosure, Exceptions, and Redisclosure Restrictions

TruLeague will not sell or use FERPA PII from education records for targeted advertising or marketing purposes, nor will it combine FERPA PII with information obtained from other sources for marketing or profiling that is unrelated to the educational services we provide on behalf of Educational Institutions.

TruLeague may access, use, and disclose FERPA PII only as authorized in writing by the Educational Institution and as permitted by FERPA, including but not limited to:

• To School Officials with a legitimate educational interest (including TruLeague personnel, contractors, and service providers performing institutional services);
• To another school where the student seeks or intends to enroll, where the Educational Institution authorizes such disclosure;
• To authorized representatives of the U.S. Comptroller General, the U.S. Attorney General, the U.S. Secretary of Education, or state and local educational authorities, in connection with audits, evaluations, or enforcement of education programs, where authorized by law;
• In connection with financial aid for which the student has applied or received, if the information is necessary to determine eligibility, amount, conditions, or enforcement of the aid;
• To organizations conducting studies for or on behalf of the Educational Institution to develop, validate, or administer predictive tests; administer student aid programs; or improve instruction;
• To accrediting organizations to carry out their accrediting functions;
• To comply with a judicial order or lawfully issued subpoena, where the Educational Institution or TruLeague (as applicable) has provided any required notice to the parent or eligible student, unless such notice is prohibited by law; and
• To appropriate officials in connection with a health or safety emergency, where knowledge of the information is necessary to protect the health or safety of the student or other individuals.

TruLeague will not redisclose FERPA PII to any other third party, except:

• To the Educational Institution itself;
• To other School Officials (including authorized sub-processors) under the direct control of the Educational Institution and subject to contractual privacy and security obligations; or
• As otherwise explicitly permitted or required by FERPA, or as explicitly instructed by the Educational Institution in a manner consistent with FERPA.

Any third parties to whom TruLeague discloses FERPA PII on behalf of an Educational Institution are contractually prohibited from redisclosing such information except as authorized by the Educational Institution and FERPA.

Recordkeeping of Disclosures

Where FERPA requires it and where TruLeague acts on behalf of an Educational Institution, TruLeague will:

• Maintain a record of each request for and each disclosure of FERPA PII from education records that TruLeague makes on behalf of the Educational Institution, including:
• The identity of the party to whom information was disclosed; and
• The legitimate interest the party had in requesting or obtaining the information; and
• Make such records available to the Educational Institution, upon its request, so that the Educational Institution can comply with FERPA’s recordkeeping obligations and respond to parent or eligible student inquiries relating to disclosures.

The Educational Institution remains responsible for maintaining its own required FERPA records for education records in its custody.

Directory Information and Opt-Out

FERPA permits Educational Institutions to designate certain categories of student information as “directory information” (for example, a student’s name, address, telephone number, email address, major field of study, participation in activities and sports, honors and awards, and dates of attendance). Directory information may be disclosed without prior consent, unless a parent or eligible student has exercised their right to opt out of such disclosures.

TruLeague does not independently designate any information as directory information. Instead:

• Each Educational Institution determines what constitutes directory information in its own FERPA notice to parents and eligible students;
• TruLeague relies on the Educational Institution’s designation and instructions regarding directory information; and
• TruLeague will not disclose directory information in a manner inconsistent with the Educational Institution’s written instructions, including any opt-out directions it communicates to TruLeague.

Parents and eligible students wishing to opt out of directory information disclosures or to learn what their institution considers directory information should contact their Educational Institution directly and follow its procedures. Where an Educational Institution notifies TruLeague that a student has opted out, TruLeague will implement the necessary changes within the TruLeague platform to honor that opt-out to the extent technically and contractually feasible.

FERPA Complaint Contact Information

If you believe that an Educational Institution has failed to comply with FERPA requirements, you have the right to file a complaint with the office that administers FERPA:

Student Privacy Policy Office (formerly Family Policy Compliance Office)
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202-8520
United States
Website: studentprivacy.ed.gov

You may also contact us with questions about how TruLeague processes education records on behalf of Educational Institutions at:

TruLeague Privacy Contact (FERPA-Related Inquiries)
Email: support@truleague.com
Postal Address: 245 Walnut Street, Unit E203, Newton, Massachusetts 02460.

Educational Institutions that use TruLeague remain responsible for providing parents and eligible students with their annual FERPA notification, defining directory information, and implementing their own FERPA policies and procedures. TruLeague supports these obligations through its role as a School Official and service provider.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: info@truleague.com

To register a complaint or concern, please contact us at privacy@truleague.com.

If you have any questions about our data protection practices, you can contact our Data Protection Officer (DPO) at:

Email: dpo@truleague.com

Address: 245 Walnut Street, Unit E203, Newton, Massachusetts 02460.

Our EU GDPR Representative

Rickert Rechtsanwaltsgesellschaft mbH

- TruLeague Incorporated -

Colmantstraße 15

53115 Bonn

Germany

art-27-rep-truleague@rickert.law