Privacy Policy

Last Updated: June 20, 2025

This Privacy Policy explains how Pebble Circle LLC ("Pebble Circle," "we," "our," or "us") collects, uses, discloses, and safeguards personal information when you visit www.pebblecircle.com (the "Site"), submit an application, or otherwise interact with our virtual mentorship and research‑simulation services (the "Program"). This Policy applies to all users, including students and their parents/guardians, mentors, and visitors.

For clarity, the following terms are used throughout both the Privacy Policy and Terms of Service:

  • "Pebble Circle," "we," "us," or "our" refers to Pebble Circle LLC, the operator of the Site and provider of the Program.

  • "Site" is the website www.pebblecircle.com, including all pages, content, and features offered through it.

  • "Program" is the online research simulation, mentorship, and educational services offered by Pebble Circle.

  • "User" or "you" is any individual who accesses the Site, submits an application, or participates in the Program, including students and their parents/guardians.

  • "Personal Information" includes data that identifies, relates to, describes, or could reasonably be linked to an individual, as defined under applicable privacy laws.

  • "Sensitive Personal Information" is a subset of personal information that includes data such as gender identity, student essays, and academic background, collected solely to provide Program services.

  • "Mentor" is a vetted individual affiliated with Pebble Circle who provides educational guidance, feedback, or instruction to students.

  • "Third-party service provider" is any external company contracted by Pebble Circle to support the Site or Program, including hosting, analytics, communication, and payment processing.

  • "Parent/Guardian" is the legal guardian of a student under 18 who consents to participation in the Program.

Definitions

Table below lists the categories of personal information we collect, the purpose for each, and whether we sell or share, as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CPRA).

Notice at Collection (California Civil Code §1798.100)

Category Examples Purpose(s) Sold/Shared?
Identifiers Name, email address, phone number, school, city & country of residence Program registration; mentor matching; communications No
Sensitive Personal Information Student’s age/grade, gender identity, application essays Program eligibility; custom learning experience No (used only to provide services)
Internet / Device Data IP address, browser type, cookie IDs Site analytics, security No
Audio/Visual Session recordings (with notice) Quality assurance; future course material (with consent) No

You have the right to: Know, Delete, Correct, Opt‑out of Sale/Share, and Limit the Use of Sensitive Personal Information. We do not sell or share personal information.

Information you provide directly via forms, account signup, email, or live sessions:

  • Student name, parent/guardian name

  • Email addresses, phone numbers

  • Country & city of residence, school name, current grade level

  • Application responses, essay questions, resume uploads

  • Payment information (processed by our third‑party provider; we never store full card numbers)

Information collected automatically:

  • IP address, device ID, cookie data, browser type/version, referring pages, time‑stamp, and usage logs (via Squarespace Analytics & Google Analytics)

Information We Collect

  • Operate, maintain, and improve the Site and Program

  • Evaluate applications and determine eligibility

  • Match students with mentors and collaborative projects

  • Communicate updates, schedules, feedback, newsletters, and marketing (with opt‑out)

  • Process payments and financial‑aid requests

  • Detect, investigate, and prevent fraud or security incidents

  • Comply with legal obligations (e.g., COPPA, FERPA‑like protections, bookkeeping)

How We Use Information

  • Directly from you (forms, emails, uploads)

  • Parents or guardians (for minors)

  • Mentors (progress evaluations)

  • Automatically via cookies and log files

Sources of Information

Sharing & Disclosure

Business Transactions

If Pebble Circle is involved in a merger, acquisition, asset sale, or other organizational restructuring, your personal information may be transferred as part of that process. We will notify you before such a transfer occurs and becomes subject to a different privacy policy.

We only disclose information as follows:

Law Enforcement

Under certain circumstances, Pebble Circle may be required to disclose your personal information if legally obligated to do so, or in response to valid requests by public authorities (e.g., court orders or government agencies).

Other Legal Requirements

Pebble Circle may disclose your information in good faith when such action is necessary to:

  • Comply with a legal obligation

  • Protect and defend the rights or property of Pebble Circle

  • Prevent or investigate potential wrongdoing in connection with our Program or Site

  • Protect the personal safety of users or the public

  • Protect against legal liability

We use first‑party and third‑party cookies for Site functionality, analytics, and to remember your preferences. You may disable cookies via your browser; however, parts of the Site may not function.

Cookies & Similar Technologies

California residents may:

  • Request to Know the personal information we collected about you in the past 12 months.

  • Request Deletion of personal information, subject to lawful exceptions.

  • Request Correction of inaccurate personal information.

  • Opt‑out of the sale or sharing of personal information (not applicable; we do not sell/share).

  • Limit the use of sensitive personal information to what is necessary to provide the Program.

  • Non‑Discrimination – We will not deny services or charge different prices for exercising your rights.

California Privacy Rights

Children’s Privacy (COPPA Compliance)

The Site is not directed to children under 13, and we do not knowingly collect personal information from them without verifiable parental consent. If we learn we have collected such data inadvertently, we will delete it. Applicants aged 13–17 must have a parent or legal guardian review and consent to participation.

We care about the protection of your personal information. However, please remember that no method of online transmission or electronic storage is completely secure. While we make every effort to protect your information, we cannot guarantee absolute security. 

Security

We retain personal information for as long as necessary to fulfill the purposes described above, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods are determined by category and legal requirements.

Data Retention

Changes to This Policy

We may update this Policy from time to time. Material changes will be posted on the Site and indicated by a new effective date. Continued use of the Site after posting constitutes acceptance.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • By email: pebblecircle@gmail.com

  • By visiting the Contact Us page of our website: www.pebblecircle.com