Guidewell Education LLC and its subsidiary Golden Pacific Education LLC (together referred to as “Guidewell,” “we,” “our,” or “us”) is committed to respecting and protecting the privacy of all individuals who interact with our services. This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with our educational offerings, websites, platforms, applications, and related services.
This policy applies across all GuideWell Education legal entities and sub-brands, including but not limited to the legal entities Guidewell Education LLC and its subsidiary Golden Pacific Education LLC , as well as its brands which all operate under these entities–UES Education, ESM Group UK, ESM Prep, Guidewell Global, Applerouth Education, College MatchPoint, Summit Education, Metro Academic Prep, Launch Precollege Labs, MBA Mission, and Reach Education (collectively, “Guidewell”). Regardless of which entity you interact with, Guidewell applies a unified set of privacy principles and safeguards.
We recognize that personal data protection requirements vary by jurisdiction. As such, this policy is structured to meet:
This Privacy Policy is intended for:
If you are a student or parent accessing our services through a school, university, or other educational institution, this policy should be read alongside the institution’s own privacy notices.
By accessing our websites or using our services, you acknowledge the practices described in this Privacy Policy. If any terms conflict with the DPF Principles, the DPF Principles will govern.
Guidewell Education LLC and its subsidiary Golden Pacific Education LLC comply with the EU–US DPF, the UK Extension to the EU–US DPF (UK–US Data Bridge), and the Swiss–US DPF as set forth by the US Department of Commerce.
Guidewell Education LLC and its subsidiary Golden Pacific Education LLC have certified to the US Department of Commerce that we adhere to the DPF Principles with respect to personal data received from the EU, UK, and Switzerland. If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit the US Department of Commerce’s website at: https://www.dataprivacyframework.gov/.
Participation in the DPF requires Guidewell Education LLC and its subsidiary Golden Pacific Education LLC to:
Our certification covers all sub-brands within the Guidewell Group, ensuring that personal data transferred under the DPF is subject to consistent protection across our organization.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Guidewell Education LLC and its subsidiary Golden Pacific Education LLC commit to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding the handling of personal data received in reliance of the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Guidewell at:
Data Protection Officer: datacompliance@guidewell.com
UK Contact: ukprivacy@guidewell.com
Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Guidewell’s internal processes, and in compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Guidewell commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to The VeraSafe DPF Dispute Resolution Program. Subject to terms of the VeraSafe DPF Dispute Resolution Program, please submit the required information to VeraSafe here:
https://verasafe.com/public-resources/dispute-resolution/submit-dispute/
These services are provided at no cost to you.
Under certain conditions specified by the EU-U.S. DPF Principles, including as applicable under the UK Extension to the EU–U.S. DPF and the Swiss-U.S. DPF Principles, you may also be able to invoke binding arbitration to resolve your complaint, as described in Annex I of the EU-U.S. DPF Principles and Annex I of the Swiss-U.S. DPF Principles.
The Federal Trade Commission has jurisdiction over Guidewell’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DFP, and the Swiss-U.S. DPF.
The EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF describe Guidewell’s accountability for personal data that it subsequently transfers to a third-party agent. Under the DPF Principles, Guidewell shall remain liable if third party agents process the personal information in a manner inconsistent with the DPF Principles, unless Guidewell proves it is not responsible for the event giving rise to the damage.
Note that Guidewell may be required to release the personal data of EU, UK and Swiss individuals in response to legal requests from public authorities, including to meet national security and law enforcement requirements.
We collect personal data directly from individuals, through our platforms, from parents/guardians, and automatically via cookies and technologies. The exact data we collect depends on your role (student, parent, mentor, visitor).
In limited cases, we may process information that qualifies as sensitive or special category data, such as:
We only process such data where strictly necessary and with appropriate legal safeguards.
We use cookies, pixels, and similar technologies to support functionality, security, analytics, and marketing. This includes:
We use personal data for defined, lawful purposes only. The ways we use personal data include:
We do not sell personal information to third parties.
For individuals located in the UK and EU, we rely on one or more of the following lawful bases to process personal data:
Under the DPF Principles, Guidewell shall remain liable if third party agents process the personal information in a manner inconsistent with the DPF Principles, unless Guidewell proves it is not responsible for the event giving rise to the damage.
We recognize that children merit special protection under data protection laws.
We do not disclose personal data except as described in this policy.
We use trusted third-party vendors under binding contracts to process data on our behalf. Categories include:
Vendors are required to process data only under our instructions and to implement appropriate safeguards.
Data may be shared between GuideWell Education LLC, its subsidiary Golden Pacific Education LLC, and their sub-brands (UES, ESM, Applerouth, CMP, Summit, MAP, Launch, Reach, MBA Mission) to provide integrated services.
We may disclose data in response to lawful requests from government agencies, courts, or law enforcement, consistent with the DPF.
GuideWell Education LLC and its subsidiary Golden Pacific Education LLC are headquartered in the United States. Accordingly, personal data may be transferred from the UK, EU, or Switzerland to the US.
We rely on:
If adequacy decisions are revoked, we will continue using SCCs with additional safeguards.
In addition to standard web technologies, Guidewell may publish llms.txt files (or similar protocol files) on our websites. These files provide instructions to automated systems, including Large Language Models (LLMs), about how our website content may be accessed, indexed, or used.
You have the right to:
US residents have rights under state privacy laws, described in Section 19.
Swiss individuals have the right to opt out of (i) disclosures of their personal data to third parties, or (ii) uses of their personal data for purposes materially different from those for which it was originally collected or subsequently authorized.
To exercise these choices, Swiss individuals may contact us at datacompliance@guidewell.com.
Swiss individuals have the right to access personal data about them that Guidewell processes under the Swiss-U.S. DPF and may correct, amend, or delete such information where it is inaccurate or processed in violation of the Principles.
To exercise any rights, contact datacompliance@guidewell.com or ukprivacy@guidewell.com. We will respond within the statutory timelines.
We use cookies and tracking technologies for:
You can control cookies through your browser or via our cookie preference center. Non-essential cookies will only be used where you consent.
We implement technical, administrative, and physical safeguards:
We regularly test and update our security practices.
We retain personal data only for as long as necessary:
When data is no longer needed, it is securely deleted or anonymized.
Guidewell may be required to disclose the personal data of EU, UK, and Swiss individuals in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We maintain an incident response plan. In case of a data breach:
Guidewell provides a free, independent dispute resolution process for individuals whose data we process under the DPF. Our selected provider is VeraSafe. If you have an unresolved privacy or data use concern, you may contact this provider directly at no cost.
As a last resort, and under certain conditions, you may invoke binding arbitration before a Data Privacy Framework Panel. This option is available after other dispute resolution mechanisms have been exhausted.
We may update this Privacy Policy from time to time. If we make material changes, we will notify users by:
The “Last Updated” date at the top of this policy reflects the most recent revision.
If you have questions, requests, or complaints, please contact us:
California residents have the right to:
We do not sell personal information. We honor opt-out requests for targeted advertising.
Virginia residents may request access, correction, deletion, portability, and opt-out of targeted advertising or profiling.
Colorado residents have rights similar to Virginia residents, with appeal rights if requests are denied.
Connecticut residents have access, correction, deletion, portability, and opt-out rights.
Utah residents may access and delete data and opt out of targeted advertising.
Nevada residents may opt out of the sale of covered information. GuideWell does not sell personal data under Nevada law.
