CounselMore Privacy Policy

counselmore.com | support@counselmore.com

Effective Date: Nov. 2025 | Last Updated: Nov. 2025

This Privacy Policy describes how CounselMore, Inc. ("CounselMore," "we," "us," or "our") collects, uses, stores, and protects information in connection with the CounselMore Platform, including the CounselMore website (CounselMore.com), web application (app.CounselMore.com), and CounselMore’s iOS and Android mobile applications (collectively, the "CounselMore Platform"). Capitalized terms used but not defined in this Privacy Policy have the meanings given in the CounselMore Terms of Service (the "Terms").

This Privacy Policy is incorporated into the Terms by reference and governs all data collection and handling practices described therein. In the event of any conflict between this Privacy Policy and the Terms, the Terms control with respect to any obligation expressly stated in the Terms. Where a user has entered into a separate private written agreement directly with CounselMore, that agreement governs where it expressly provides otherwise; the Terms govern all remaining obligations; and this Privacy Policy governs data collection and handling practices not expressly addressed in either. If you do not agree to this Privacy Policy, you must discontinue use of the CounselMore Platform.

1. Scope and Who This Policy Covers

This Privacy Policy covers information collected from registered users of the Platform (“Users”) and information that Users enter into the Platform in the course of their professional practice, including information pertaining to their student and family clients.

This Privacy Policy does not apply to information collected offline, to third-party websites or services linked from the Platform, or to information governed by a separate written agreement between CounselMore and an institutional user. Where a separate written agreement expressly addresses data handling, that agreement governs to the extent it conflicts with this Privacy Policy.

2. Information We Collect

A. Account and Professional Information

When you register for and use the CounselMore Platform, we collect information you provide directly, including:

• Your name, professional title, business name, and email address
• Your billing address and payment information (processed securely by Stripe — see Section 8)
• Account credentials including your username and password
• Your geographic location or time zone, as provided during registration
• Communications you send to CounselMore, including support requests, feedback, and correspondence

You are solely responsible for providing accurate and complete information and for maintaining the accuracy of that information throughout your subscription.

B. Student and Client Data Entered by Users

The CounselMore Platform enables professional users to create and manage profiles, records, college lists, case notes, and related materials for their student and family clients. This information is entered into the Platform exclusively by the professional user under the professional’s account. CounselMore does not directly collect information from students or their families.

For all student and client information entered into the Platform by a User, CounselMore functions solely as a data processor acting on behalf of the User. The User determines what data is collected, entered, stored, and used within the Platform and is the data controller for that information.

The special protections applicable to K-12 student personally identifiable information are described in Section 4 below.

C. Platform Usage and Technical Data

We may collect certain technical and usage data automatically when you access or use the CounselMore Platform, including:

• IP address, browser type, operating system, and device identifiers
• Pages and features accessed, session duration, and navigation patterns
• Error logs and diagnostic data used to maintain and improve platform performance
• Cookies and similar tracking technologies (see Section 9)

This technical data is collected for the purpose of operating, maintaining, securing, and improving the CounselMore Platform. It is not used to build individual behavioral profiles for advertising purposes.

D. Information from Third-Party Sign-In Services

You may log in to the CounselMore Platform using Google Login. When you do so, the Google authentication service authenticates your identity and may share certain information with CounselMore, such as your name and email address, to pre-populate your account registration. CounselMore does not access, read, or collect your Google Account documents, email, or files through Google Login unless you separately and expressly send those materials to CounselMore.

E. Google Drive Integration

You may choose to link your Google Drive to your CounselMore account. This integration requires read/write access to your Google Drive to enable document access on your behalf. A randomized identifier masks each linked folder and is stored securely. CounselMore does not access, read, or collect Google Drive documents or files unless you send them to CounselMore through a user-initiated action within the Platform. The Google Drive integration is optional and user-controlled.

3. How We Use Information

CounselMore uses the information it collects for the following purposes:

• To create and maintain your CounselMore Account and deliver the CounselMore Services to your account
• To process payments and manage billing through our third-party payment processor, Stripe
• To perform technical functions including backup, security monitoring, and error correction
• To respond to your support requests, inquiries, and correspondence
• To contact you with notices regarding your account, these Terms, this Privacy Policy, or material changes to the Platform
• To investigate and address suspected or confirmed security incidents, fraud, or violations of the Terms
• To comply with applicable legal obligations and respond to lawful requests from governmental or regulatory authorities
• To operate, maintain, and improve the CounselMore Platform based on aggregated and anonymized platform activity

CounselMore does not use User Content, student data, or client data to train artificial intelligence or machine learning models, to develop commercial data products, to provide services to other users or third parties, or for any purpose beyond delivering the CounselMore Services to your account.

4. K-12 Student Personally Identifiable Information

Confidentiality and Protection

CounselMore recognizes that User Content entered into the Platform may include personally identifiable information pertaining to K-12 students who are minors. CounselMore treats all K-12 student personally identifiable information as confidential and applies its full data security framework to that information. CounselMore does not treat K-12 student personally identifiable information as a lower-sensitivity category for any purpose.

What We Do Not Do With K-12 Student Data

CounselMore does not:

• Share K-12 student personally identifiable information with advertising networks, marketing partners, or data brokers
• Use K-12 student data to train artificial intelligence or machine learning models
• Develop commercial data products from K-12 student data
• Share K-12 student data with any third party whose services are not essential to delivering the CounselMore Services to your account
• Use K-12 student data for any purpose other than enabling you to deliver educational counseling and advising services through the CounselMore Platform

FERPA

Where CounselMore serves school-based counselors or institutional clients, it operates solely as a technology service provider. Users are solely responsible for their own compliance with the Family Educational Rights and Privacy Act (FERPA), applicable state education records laws, and any other laws governing the handling of student educational records. CounselMore will make its data handling practices available to users upon reasonable written request.

COPPA and Students Under 13

CounselMore does not knowingly permit the entry of personally identifiable information pertaining to any student under the age of 13. By using the Platform, you represent and warrant that you will not submit personally identifiable information pertaining to any student under the age of 13. Compliance with the Children's Online Privacy Protection Act (COPPA) and any applicable state law with respect to student data entered into the Platform is solely your responsibility as the professional user.

K-12 Student Data Deletion

Where a user elects to permanently cancel their CounselMore Account, CounselMore will delete all K-12 student personally identifiable information within a commercially reasonable period following the cancellation form submission date. Deleted data cannot be recovered. Users are responsible for exporting any data they wish to retain prior to submitting a cancellation form.

5. How We Share Information

No Sale. No Advertising.

CounselMore does not sell, rent, or trade personal information or User Content to any third party. CounselMore does not share personal information or User Content with advertising networks, marketing platforms, or data brokers for any purpose. Non-personally identifiable, aggregated data derived from platform activity may be used internally by CounselMore to improve the Platform and may be displayed to active paying subscribers within the Platform as a service feature. Such aggregated data is not individually identifiable, cannot be traced to any specific counselor or student, and is not shared outside the Platform, sold, or transferred to any third party for any purpose.

Essential Service Providers

CounselMore shares information with third-party service providers only to the extent strictly necessary to operate the Platform. These service providers are contractually required to handle information in a manner consistent with their role delivering the CounselMore Services and are not permitted to use information for any other purpose. Current essential service providers include Google (cloud infrastructure), Stripe (payment processing), Calendly, (scheduling integration, where user-enabled), and Acuity (scheduling integration, where user-enabled). This list may be updated as standard platform infrastructure evolves. Payment processors do not receive K-12 student personally identifiable information through ordinary subscription billing flows.

User-Controlled Third-Party Integrations

The CounselMore Platform offers optional third-party integrations, including scheduling, calendar, and productivity tools. These integrations are user-initiated. You choose which third-party services to connect to your account. CounselMore transmits data to a connected third-party service only when you direct it to do so, such as when you initiate a sync, export, or integration action within the Platform. CounselMore does not push or pull data between your account and any connected third-party service without a user-initiated action. CounselMore is not responsible for the data practices of third-party services you choose to connect to, and you should review the privacy policy of each third-party service before connecting it to your account.

Legal Requirements and Safety

CounselMore may disclose information where required to do so by law, regulation, court order, subpoena, or other governmental or legal process. CounselMore may also disclose information where it believes in good faith that disclosure is necessary to: protect the rights, property, or safety of CounselMore, its users, or the public; investigate or prevent fraud, security incidents, or violations of the Terms; or comply with applicable legal obligations. Where permitted by applicable law and operationally practicable, CounselMore will endeavor to notify affected users of lawful requests for their data, but assumes no contractual obligation to do so.

Business Transfers

In the event of a merger, acquisition, sale of assets, reorganization, or similar transaction involving CounselMore, User Content and personal information may be transferred to the acquiring entity or successor. Any such transfer is conditioned on the assignee or successor expressly assuming CounselMore’s obligations with respect to User Content ownership and K-12 student personally identifiable information as set forth in the Terms. Users will be notified of any such transaction in accordance with the notice provisions of the Terms.

6. Community Content and Anonymous Annotations

Counselor-generated opinions and annotations entered voluntarily into community-facing features of the CounselMore Platform remain the User Content of the contributing counselor. By voluntarily entering such content, you grant CounselMore a limited license to display that content anonymously to other active CounselMore subscribers as a community feature within the Platform. This anonymous display occurs solely within the CounselMore Platform and does not constitute disclosure to any party outside the Platform. CounselMore does not sell, transfer, or share community annotations with any third party. You are solely responsible for ensuring that any opinions or annotations you enter do not contain information that could be used to identify a specific student or family.

7. Feedback and Support Communications

If you submit suggestions, comments, or feedback relating to the CounselMore Platform, CounselMore may use that feedback to develop and improve the Platform, provide support, create aggregated statistical data, enhance security, and comply with legal obligations. The use of feedback is also governed by the license terms set forth in the Terms of Service, which users should review for the complete scope of CounselMore’s rights with respect to submitted feedback. Feedback does not include K-12 student personally identifiable information, student educational records, or counseling case materials. Where a support request or communication includes such information, that information is governed exclusively by the User Content provisions of the Terms and by this Privacy Policy.

8. Payment Processing

Payments on the CounselMore Platform are processed by Stripe. CounselMore does not store full credit card numbers on its own systems. Your payment information is transmitted directly to and stored by Stripe in accordance with applicable PCI-DSS standards. Stripe’s privacy policy is available at https://stripe.com/privacy. CounselMore receives transaction confirmation and billing identifiers from Stripe for purposes of account management. Payment processors do not receive K-12 student personally identifiable information through ordinary subscription billing flows.

9. Cookies and Tracking Technologies

CounselMore may use cookies and similar tracking technologies to operate and improve the Platform. Cookies are small data files placed on your device that allow the Platform to recognize your browser and store certain preferences or session information. CounselMore uses cookies and similar technologies for the following purposes:

• To maintain your authenticated session and account preferences
• To analyze usage patterns and improve platform performance
• To detect and prevent fraud and security incidents
• To compile aggregate, non-personally identifiable data about platform traffic and user activity

CounselMore may also use third-party analytics tools, including Google Analytics, to collect and analyze aggregate usage information. These tools may use cookies, beacons, scripts, and similar technologies. Google Analytics’ data practices are governed by Google’s Privacy Policy, available at https://policies.google.com/privacy. CounselMore encourages you to review Google’s privacy terms to understand how Google collects and uses data through its analytics services.

You may configure your browser to decline cookies or to alert you when a cookie is being set. Disabling cookies may affect the functionality of certain features of the CounselMore Platform. CounselMore does not serve advertising through cookies or use cookie data to deliver targeted advertising.

10. Do Not Track

Some browsers transmit Do Not Track signals to websites. Because no uniform standard for Do Not Track signals has been adopted, the CounselMore Platform does not currently process or respond to Do Not Track signals. CounselMore does not track user behavior across third-party websites for advertising purposes.

11. Data Retention

CounselMore retains your account and professional information for as long as your account is active or as necessary to fulfill legitimate business and legal purposes, including to resolve disputes, enforce agreements, and comply with legal obligations.

Upon cancellation or termination of your account, data is handled as follows:

• K-12 student personally identifiable information is deleted within a commercially reasonable period not to exceed thirty (90) days following the cancellation form submission date, absent extraordinary operational circumstances. Backup copies of K-12 student personally identifiable information are subject to the same deletion obligation and are deleted or overwritten within the same thirty (0) day period applicable to active data.
• Professional account data — including counseling materials, settings, and platform content that does not constitute K-12 student personally identifiable information — may be preserved in dormant status at CounselMore’s discretion, or may be deleted. Dormant data is subject to the limited license described in the Terms solely to the extent necessary for CounselMore to maintain, secure, and store it.
• Backup copies of deleted data may persist in archived systems for a limited period consistent with CounselMore’s standard backup and disaster recovery practices.

Users are responsible for exporting any data they wish to retain prior to submitting a cancellation form. CounselMore is not liable for any loss of data resulting from a user-initiated cancellation.

12. Security

CounselMore maintains commercially reasonable administrative, technical, and physical safeguards designed to protect User Content and personal information from unauthorized access, disclosure, alteration, or destruction. These safeguards are applied consistently across all categories of data CounselMore handles, with K-12 student personally identifiable information subject to CounselMore’s full security framework without exception.

No method of electronic transmission or storage is 100% secure. CounselMore cannot guarantee the absolute security of information during transmission or storage. In the event of a security incident affecting your data, CounselMore will respond in accordance with its obligations under applicable law. Where permitted by applicable law and operationally practicable, CounselMore will endeavor to notify affected users of confirmed security incidents affecting their data.

13. Your Rights and Choices

As a registered User, you may access, review, and update your account information at any time by logging in to your CounselMore account and updating your profile, or by contacting CounselMore at support@counselmore.com.

You may request deletion of your account and associated personal information by following the cancellation procedure described in the Terms. CounselMore will make commercially reasonable efforts to delete your personal information consistent with its data retention obligations; however, deletion of personal information does not ensure complete and comprehensive removal from all backup or archived systems.

California residents may have additional rights under the California Consumer Privacy Act (CCPA) or successor statutes, including the right to know what personal information is collected, the right to request deletion, and the right not to be discriminated against for exercising privacy rights. CounselMore does not sell personal information and does not share personal information for cross-context behavioral advertising. Because CounselMore does not engage in either practice, no opt-out mechanism for the sale or sharing of personal information exists or is required. California residents may direct privacy rights requests to support@counselmore.com. Please note that service-related communications — including responses to support requests, billing notices, account alerts, and platform updates — are necessary to deliver the Services you have purchased and are not subject to marketing opt-out preferences. Under the federal CAN-SPAM Act (15 U.S.C. § 7702 et seq.), transactional and relationship messages necessary to complete a transaction or service a subscription are categorically exempt from commercial email opt-out requirements. When you contact CounselMore at support@counselmore.com, you are initiating a service communication and CounselMore will respond to that communication using the contact information associated with your account. Opting out of marketing communications does not affect CounselMore’s ability or obligation to send transactional and service communications required to maintain your account and deliver the CounselMore Services.

14. International Data Transfers

The CounselMore Platform is operated by CounselMore, Inc., a company incorporated in Delaware and operating in the State of California, United States. All platform data is stored and processed in the United States. CounselMore serves professional users in the United States and internationally, including users in the European Union and other jurisdictions with data protection frameworks that differ from United States law. CounselMore operates as a closed system with respect to student and client data — data entered by professional users remains within the CounselMore Platform and is not transferred internationally by CounselMore. User account information necessary to operate and maintain a CounselMore account is processed in the United States. By using the Platform and providing your information, you consent to the transfer, storage, and processing of your account information in the United States. Users in the European Union or other jurisdictions with applicable data protection law should be aware that their personal account data is processed by a United States entity. CounselMore acknowledges that EU residents may have rights under the General Data Protection Regulation (GDPR) with respect to their personal account information and encourages EU-based users to contact support@counselmore.com with any data rights inquiries. CounselMore’s third-party service providers, including Google and Stripe, may also process data in other countries in accordance with their own privacy policies.

15. Changes to This Privacy Policy

CounselMore reserves the right to modify this Privacy Policy at any time. Updated versions will be clearly posted within the CounselMore Platform or on the CounselMore website. Continued use of the Platform following such posting constitutes acceptance of the revised Privacy Policy.

16. Contact Information

If you have questions about this Privacy Policy, wish to exercise a privacy right, or have a concern about CounselMore’s data practices, please contact:

CounselMore, Inc.

Privacy Team

support@counselmore.com

counselmore.com

200 Industrial Road, Suite #128, San Carlos, CA 94070

CounselMore will respond to privacy-related inquiries within a commercially reasonable time. Any dispute arising out of or relating to this Privacy Policy is subject to the Governing Law, Dispute Resolution, and Binding Arbitration provisions of the CounselMore Terms of Service, including the binding arbitration clause and class action waiver set forth therein.

This Privacy Policy is incorporated into and subject to the CounselMore Terms of Service.

CounselMore, Inc. | counselmore.com | support@counselmore.com