Phoenix Education Partners

PHOENIX EDUCATION PARTNERS, INC. PRIVACY POLICY

Last Updated: 9/23/2025

This Privacy Policy (“Policy”) describes the information collected by or on behalf of Phoenix Education Partners, Inc. (“Phoenix Education Partners” “we,” “us,” or “our”) through our website phoenixeducationpartners.com (“Site”) and our interactions with you, and how the information is used, protected and disclosed.

We may modify this Policy at any time. All changes will be effective immediately upon posting to the Site. When we determine that a modification is material, we will provide notice of the changes to you via the Site and may otherwise communicate the changes to you via email. We will not ordinarily provide notice of minor changes.

State Supplemental Privacy Notice. Certain states provide for different privacy rights and disclosures. These rights and disclosures are set forth in our State Supplemental Privacy Notice. If you are a California resident, please see the California Privacy Rights Notice below for additional rights and terms that may apply to you.

If you have any questions or concerns about this Policy, please contact compliance@phoenixeducationpartners.com.

1. Scope of this Policy

This Policy applies to information that Phoenix Education Partners may collect that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”) when you use our Site, and otherwise interact with us (collectively, “Services”).

This Policy only applies when Phoenix Education Partners collects and/or processes Personal Information for Phoenix Education Partners purposes and does not apply to the Personal Information collected by our subsidiaries or affiliated entities, including the University of Phoenix, Inc. or Talent Mobility, LLC. You may review the privacy practices of University of Phoenix, Inc. by visiting its Privacy Policy and the privacy practices of Talent Mobility, LLC d/b/a Skillmore by visiting its Privacy Policy.

2. Information We Collect

The information we collect falls into the following categories: (a) information you provide to us; and (b) information we collect through automated methods when you use our Services (each as further detailed below).

You can visit the Site without submitting Personal Information. However, Personal Information is required to use certain Services, for example, to contact us via email or phone (where we may retain your message’s content and our response) and to receive or request data from us (e.g., earnings reports). In such circumstances, we may be unable to provide you with our Services unless you provide your Personal Information.

Information You Provide to Us

We collect Personal Information that you provide directly to us. If you elect to provide data that personally identifies you such as your name, email address, mailing address, and phone number, or any other similar information, we will collect, use, and disclose such Personal Information pursuant to this Policy and applicable law. This may occur in the following ways:

The Site. We collect Personal Information that you may submit to us when using our Site and online services. If you choose to subscribe to our email alerts or request other information from us, we may collect your name and email address to send you the requested alerts. You may unsubscribe from these communications at any time by following the instructions provided in the email or by using the unsubscribe feature available on our website.

Communications with Us. If you communicate with us, such as through our online contact us webform, we will collect any Personal Information that you elect to provide to use during, or because of, those communications, such as name, phone number, email address, and message content.

Data Automatically Collected

We may use automated technologies to collect Personal Information from your computer system or mobile device when you use certain portions of our Site. This may include the following:

Site Activity. We may collect Personal Information about how you use Site. We may combine this Personal Information automatically collected from you with other Personal Information.

Tracking Technologies. Our Site may use cookies, web beacons, pixel tags and other tracking technologies (collectively "Tracking Technologies"). A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

Most browsers automatically accept Tracking Technologies. You can disable this function by changing your browser settings but disabling certain Tracking Technologies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Tracking Technologies. You cannot disable all Tracking Technologies, such as Tracking Technologies that are essential to the functioning of the Site.

The Tracking Technologies on certain portions of our Site may collect information such as:

IP addresses assigned to the computers and other devices you use;
your internet service provider;
device ID number;
approximate geographic location;
browser type;
Site pages visited;
websites you access before and after visiting the Site, and
data related to how and when you use the Site.

CALIFORNIA'S "DO-NOT-TRACK" REQUIREMENT. WE CURRENTLY DO NOT HONOR “DO NOT TRACK” SIGNALS.

Google Analytics. We use Google Analytics to collect and process information about your use of the Site. Google sets Tracking Technologies on your browser or device, and your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site. To learn more about how Google uses data, visit Google’s Privacy Policy and you can learn about how Google uses data from third party websites here. You may download the Google Analytics Opt-out Browser Add-on for each web browser that you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

reCAPTCHA. We may use and implement reCAPTCHA, a Google tool to help fight spam and misuse on our Site. Use of reCAPTCHA is subject to Google’s Terms of Service and Privacy Policy. As a result, certain Personal Information may be disclosed to and collected by Google for this purpose.

3. How We Use Your Information

We use Personal Information that we collect for the following purposes:

As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you such as when you subscribe to receive our public filings, annual reports, stock price updates, or news alerts about us.

Administration and Business Analytics. We may use Personal Information for administrative purposes and to collect business analytics, such as to inform our business strategies, to understand the Site’s demographics and user preferences, to conduct consumer and operations research, to assess the effectiveness of our online services, and to analyze market trends and future consumer demand.

Communications. We may use Personal Information to notify you of new services, products, or programs, to notify you of new features of our Site, to notify you of changes to our terms or this Policy, and for other similar communications.

Site Management. We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and customizing the Site to you and our users.

Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.

To Create Anonymized or De-identified Data. We may process Personal Information to create de-identified or anonymized data that can no longer identify you. We may collect, use, disclose, transfer, and otherwise process such de-identified or anonymized information that we receive or create for any purposes in our sole discretion. Anonymized and/or de-identified data is no longer considered Personal Information and is not covered by this Policy.

How We Use Data Collected by Tracking Technologies. We use Tracking Technologies to: (i) make our Site function properly; (ii) provide personalized experiences; (iii) tailor our interactions with you; (iv) provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and (v) help us improve our Services.

4. Disclosure of Personal Information

Phoenix Education Partners does not (i) sell Personal Information for money; (ii) engage in targeted advertising; or (iii) engage in profiling in furtherance of our decisions that produce legal or similarly significant effects, such as decisions that result in the provision of any employment or educational opportunities to you.

However, we may disclose Personal Information with the following categories of third parties:

Subsidiaries and Affiliates. We may disclose Personal Information with our subsidiaries and affiliates who have a need to know the information for our business purposes.

Service Providers and/or Third Parties. We may disclose Personal Information with our vendors and service providers that provide services for us. For example, we may disclose Personal Information with service providers to help us host and manage the Site; improve the content and functionality of the Site; perform data analysis and statistical analysis; troubleshoot problems with the Site; and support or provide the security of the Site.

Government Officials and/or Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Phoenix Education Partners or any other party.

Professional Advisors. We may disclose Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to Phoenix Education Partners.

Change in Ownership. In the event Phoenix Education Partners is the subject of a change of control or in the event the Site changes ownership, in whole or in part, or in the event of bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s).

Other. We may disclose Personal Information with 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).

5. Retention of Personal Information

We will keep Personal Information for the period necessary to fulfil the purposes described in this Policy unless a longer retention period is permitted or required by law.

6. Children's Information.

The Site is not directed at children under 18 years of age. We do not knowingly collect, sell, use, or share Personal Information from children under 18. If we obtain actual knowledge that any personal information we collect has been provided by a child as defined by applicable law, we will promptly delete that information. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.

7. Data Security

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.

8. Social Media

We are active on social media, including Meta, LinkedIn, X, and other similar sites (“ Social Media ”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on Social Media platforms. Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those platforms and not by this Policy. We encourage you to review those policies and terms.

9. Third-Party Websites

In addition to Social Media, the Site may link to, or be linked to, websites not controlled by us. We are not responsible for third parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

10. Access from Outside the United States

If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.

STATE SUPPLEMENTAL PRIVACY NOTICE

This State Supplemental Privacy Notice explains how to exercise consumer privacy rights you may have under the laws of your state (“ State Privacy Laws ”). This State Supplemental Notice is only intended to supplement the Policy. Please refer above to find detailed information about Information We Collect, How We Use Your Information, and Disclosure of Personal Information along with additional information about our privacy practices.

Consumer Privacy Rights Under State Privacy Laws

Subject to certain exceptions, you may have some or all the following rights under State Privacy Laws:

Right to Request Access. You have the right to confirm whether we are processing your Personal Information and to access such Personal Information. Depending on your state of residence, you may also have the right to receive a list, of specific third parties with whom we disclose Personal Data.
Right to Request Data Portability. You have the right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without hindrance, where the processing is carried out by automated means.
Right to Know. The right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
Right to Request Correction. The right to request that we correct inaccurate Personal Information that we maintain about you.
Right to Request Deletion. The right to request that we delete your Personal Information that we have collected from or about you.
Right to Non-Discrimination. The right not to receive discriminatory treatment for exercising your privacy rights.

How to Exercise Your Rights Under State Privacy Laws

To submit a request to exercise any of the rights above, you may submit your request to us by emailing compliance@phoenixeducationpartners.com. Alternatively, you may call 866-808-3095 (US Toll Free).

You must provide sufficient information to allow us to reasonably verify you are the individual to whom the Personal Information relates, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

When we receive your rights request (i) we will acknowledge receipt of your request; (ii) we will try to match the information you provide in making the request with information we already maintain about you; (iii) in order to verify your identity, we may ask you to provide additional information, which may include Personal Information; and (iv) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, and the likelihood of fraud.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request and let you know why. In addition, we may decline to comply with your request as permitted by the applicable State Privacy Laws. We may charge a fee as permitted by the applicable State Privacy Laws, such as to process or respond to your request if it is excessive, repetitive, manifestly unfounded, or if we believe the request is fraudulent or submitted for purposes other than exercising applicable privacy rights.

Some State Privacy Laws permit the submission of consumer requests by an authorized agent. If we receive a request from an authorized agent, we will need to verify and authenticate your identity as the data subject, the agent’s identity, and the agent’s authority to act on your behalf. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf or if applicable State Privacy Laws do not permit requests by anyone other than you.

Furthermore, a parent or legal guardian may make a request on behalf of their dependent or non-adult child. We may deny a request if you are unable to prove that you are the custodial parent or legal guardian.

If we reject or deny your request, you may appeal our decision within 30 days of receiving our denial by responding directly to the communication denying your request or by submitting your appeal to compliance@phoenixeducationpartners.com.

CALIFORNIA PRIVACY RIGHTS NOTICE FOR CALIFORNIA RESIDENTS

THIS SECTION PROVIDES ADDITIONAL PROVISIONS APPLICABLE ONLY TO RESIDENTS OF CALIFORNIA.

If any information in this section conflicts with the main body of this Policy above, the information in this Section controls for California residents. Capitalized terms used in this state- specific section but that are not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 and its implementing regulations (collectively, the “CCPA”).

Collection, Sources, Purpose, Sharing and Retention of Your Personal Information

Categories of Personal Information We Collect. We may collect the following categories of Personal Information:
- Identifiers consisting of: real name, postal address, online identifier, internet protocol address (“IP Address”), email address, or other similar identifiers.
- Internet Activity consisting of: browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
- Employment Information: Professional or employment-related information.
Categories of sources from which Personal Information is collected. The categories of sources from which Personal Information is collected is described in Section 1 (Information We Collect).
Purposes for collecting Personal Information.The purposes for collecting Personal Information are described in Section 2 (How We Use Your Information).
Categories of Service Providers and Third Parties to Whom Personal Information is Disclosed for a Business Purpose. We may disclose all of the categories of Personal Information described above in this Section for our business purposes. The categories of third parties and/or service providers with whom we may disclose Personal Information to are described in Section 3 (Disclosure of Personal Information).
Categories of Third Parties Personal Information Sold or Shared. In the last 12 months we have not Sold or Shared Personal Information (each as defined under CCPA) of any individual for compensation or cross-contextual behavioral advertising and we currently do not Sell or Share Personal Information.
We do not have any actual knowledge of selling or sharing Personal Information of any individual under the age of 16 for monetary compensation or for cross-context behavioral advertising.
Sensitive Personal Information. We have not used or disclosed Sensitive Personal Information for any reason other than the reasons for which it was provided to us. We do not use Sensitive Personal Information to infer characteristics about individuals.
Data Retention. We determine how long to retain Personal Information, which applies to all categories of Personal Information, based on our legal obligations, how long we need to retain your Personal Information for the purposes we collected it, and our internal data retention policies.

California Consumer Data Rights

Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, if you are a California resident, you may exercise the following rights regarding your Personal Information:

Right to Request Access. You have the right to request access to, and receive a copy of, the specific pieces of Personal Information that we have collected about you.
Right to Request to Know. You have a right to request information about the Personal Information we have collected about you, including any of the following:
- the categories of Personal Information we collected from you,
- the categories of sources from which the Personal Information was collected,
- the business or commercial purpose for collecting, Selling or Sharing your Personal Information,
- the categories of third parties with whom we disclosed, Sold or Shared your Personal Information,
- the specific pieces of Personal Information we collected from you, and
- a list of categories of Personal Information we Sold, Shared or disclosed for a Business Purpose.
Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you. We will comply with such requests, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
Right to Opt-Out of the Sale or Sharing of Your Personal Information. You have the right to request that we do not Sell or Share any Personal Information. As noted above, we do not “Sell” or “Share” any Personal Information as defined by CCPA.
Right to Request Correction of Inaccurate Personal Information. You have the right to request that we correct inaccurate Personal Information that we maintain about you. We will make commercially reasonable efforts to make any such corrections as required by applicable law.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to limit our use and disclosure of your Sensitive Personal Information to only uses that are necessary to perform the Site Sav-Rx provides to you. We do not use or disclose Sensitive Personal Information for any purpose other than the purpose for which it was collected.
Right to Non-Discrimination. You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA. Should you wish to exercise any of your rights as detailed above, we will not discriminate against you by offering you different services based solely upon your exercise of the above rights.

How to Exercise Your California Consumer Rights

Submitting a Request. To exercise your California rights described in this Section, you may submit your request to us by emailing us at compliance@phoenixeducationpartners.com.
Verifiable Consumer Request. To verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. This information may vary depending on the Personal Information we already have. We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request and let you know why.
Authorized Agents. You may only make a request to exercise your rights on behalf of yourself, or a parent or legal guardian may make a request on behalf of their child. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to be your agent and to make the specific request submitted, unless the agent is subject to a Power of Attorney under California probate laws. If the agent is a Power of Attorney under California probate laws, we may require evidence of that status.
When We Will Respond. We will confirm receipt of your request within 10 business days. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Denial and Right to Appeal. We may deny your request if permitted by CCPA. If we deny your request, you will have the right to appeal within thirty (30) days of our sending the denial by responding directly to the communication denying your request or by emailing us at compliance@phoenixeducationpartners.com.