1. Introduction
This Privacy Policy explains how TJLim Co., LLC, a Wyoming limited liability company doing business as Student Excellence Foundation ("SEF", "we", "our", or "us"), collects, uses, shares, and protects personal information when you use our website, platform, and related services (collectively, the "Service").
By using the Service, you consent to the practices described here. If you do not agree, please do not use the Service. This Policy works together with our Terms of Service.
Despite the word "Foundation" in our brand name, SEF is operated by TJLim Co., LLC, a for-profit limited liability company, and is not a non-profit or charitable organization.
2. Information We Collect
2.1 Information You Provide Directly
- Account information: name, email address, password, school name, and grade level.
- Profile information: any additional details you choose to add to your profile.
- Application information: answers, essays, file attachments, and other materials you submit when applying for a Competition or Cohort.
- Communications: messages and contact-form submissions you send to us.
2.2 Payment Information
When you pay an Entry Fee, you submit payment details (such as your card number, expiration date, and CVC) directly to our payment processor. SEF does not receive or store your full payment card number, CVC, or expiration date. We receive only non-sensitive payment metadata, such as:
- Transaction status, amount, currency, and timestamp.
- A payment processor identifier (e.g., checkout ID, transaction ID, customer ID).
- The billing email and, in some cases, country/region used for tax determination.
See Section 5 below for more on our payment processor relationship.
2.3 Information Collected Automatically
- Usage data: pages visited, features used, links clicked, and time spent on the Service.
- Device and connection information: IP address, browser type and version, operating system, device identifiers, and referring URLs.
- Cookies and similar technologies: see Section 9.
2.4 Information From Third Parties
If you sign in using Google OAuth, we receive basic profile information (name, email, and profile picture) from Google in accordance with the permissions you grant and Google's privacy terms. We may also receive aggregate analytics information from third-party services like Google Analytics.
3. How We Use Your Information
We use the information we collect to:
- Create and operate your account and authenticate you.
- Process Entry Fee payments and provide receipts.
- Process and evaluate your Competition applications.
- Communicate with you about Competitions, results, account activity, payment confirmations, refunds, and platform updates.
- Improve, debug, secure, and personalize the Service.
- Prevent fraud, enforce our Terms, and respond to legal requests.
- Comply with applicable laws, regulations, and tax obligations.
4. How We Share Your Information
We do not sell your personal information. We share information only in the limited circumstances below:
- With Competition Organizers: your application materials and contact information are shared with the Organizer of any Competition you apply to, for the purpose of evaluating your application and contacting you with results.
- With our payment processor: see Section 5.
- With service providers: trusted vendors that process data on our behalf for hosting, infrastructure, analytics, email delivery, and customer support, bound by confidentiality and data-processing obligations.
- For legal reasons: when required by law, subpoena, court order, or to protect the rights, property, or safety of SEF, our users, or others, including to investigate fraud or abuse.
- Business transfers: in connection with a merger, acquisition, financing, reorganization, or sale of assets, in which case the recipient must honor commitments made in this Policy.
- With your consent: in any other case where you direct us to share information.
5. Payment Information and Payment Processor
Payments on the Service are processed by Creem, which acts as our Merchant of Record. This means Creem is the seller of record for your transaction, handles card processing, tax compliance, and remittance, and is responsible for chargeback risk.
When you complete a checkout, the card data you enter is collected directly by Creem on its hosted checkout page and is subject to Creem's privacy policy. We share with Creem only the information necessary to create the checkout (such as your user ID, the Competition and Cohort identifiers, and the amount). We receive back from Creem only the non-sensitive metadata described in Section 2.2. Creem may share information with us, with payment card networks, and with banks and tax authorities as needed to process the transaction and meet legal requirements.
For more information about Creem's terms and privacy practices, please review:
6. Data Retention
We retain personal information only for as long as necessary for the purposes described in this Policy. Typical retention timeframes are:
- Account information: while your account is active. After you request deletion, we delete or anonymize your account within thirty (30) days, except as noted below.
- Application content: for the duration of the Competition and a reasonable period afterward (typically up to twenty-four (24) months) so that Organizers can manage results and appeals.
- Payment records: retained for at least seven (7) years to meet tax, accounting, and audit obligations, as required by U.S. law.
- Communication records and logs: retained for up to twenty-four (24) months for security, fraud prevention, and audit purposes.
We may retain information longer where required by law, to resolve disputes, to prevent fraud and abuse, or to enforce our Terms.
7. Your Rights and Choices
Depending on your location and applicable law, you may have the following rights:
- Access: request a copy of the personal information we hold about you.
- Correction: request that inaccurate or incomplete information be corrected.
- Deletion: request deletion of your personal information, subject to legal exceptions (e.g., we may retain payment records for seven years).
- Portability: receive a copy of certain information in a portable format.
- Opt-out of marketing: unsubscribe from marketing emails at any time using the link in the email. Transactional emails (e.g., payment receipts, application confirmations) will continue while your account is active.
- Withdraw consent: where processing is based on consent, withdraw that consent at any time.
To exercise any of these rights, email [email protected] from the email associated with your account. We may need to verify your identity before fulfilling certain requests. You will not be discriminated against for exercising your rights.
8. California Residents' Rights
If you are a California resident, the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA") provides additional rights regarding your personal information.
8.1 Categories of Personal Information Collected
In the past twelve (12) months we may have collected the following categories of personal information about California residents:
- Identifiers (e.g., name, email address, IP address, account ID).
- Customer records information (e.g., school name, grade level).
- Commercial information (e.g., Entry Fees paid, Competitions applied to).
- Internet and other electronic network activity information (e.g., browsing actions on the Service, device information).
- Inferences drawn from the above (e.g., aggregated usage patterns).
- Education information (e.g., school, grade, application content) — to the extent you provide it.
8.2 Sources, Purposes, and Disclosures
We collect this information from the sources and for the purposes described in Sections 2 and 3, and disclose it to the recipients described in Sections 4 and 5. We do not knowingly collect sensitive personal information beyond what is reasonably necessary to operate the Service, and we do not use sensitive personal information for inferring characteristics about you.
8.3 Sale and Sharing
We do not sell personal information and do not share personal information for cross-context behavioral advertising (as those terms are defined under the CCPA/CPRA). We do not have actual knowledge of selling or sharing personal information of consumers under sixteen (16) years of age.
8.4 Your CCPA/CPRA Rights
- Right to know what personal information we collect, use, disclose, and share.
- Right to request deletion of your personal information.
- Right to correct inaccurate personal information.
- Right to limit the use and disclosure of sensitive personal information.
- Right to opt out of any sale or sharing (not applicable as we do not sell or share).
- Right to non-discrimination for exercising your rights.
To exercise these rights, contact us at [email protected]. You may also designate an authorized agent to make a request on your behalf, subject to verification.
9. Cookies and Tracking Technologies
We use cookies and similar technologies, which fall into the following categories:
- Strictly necessary: required to operate the Service (e.g., session, authentication, CSRF protection). These cannot be turned off through the Service.
- Functional: remember your preferences and settings.
- Analytics: help us understand how users interact with the Service (e.g., Google Analytics 4) so we can improve it. These collect aggregated, mostly non-identifying information.
You can control most cookies through your browser settings, including blocking or deleting them. Disabling strictly-necessary cookies may prevent the Service from functioning. We do not currently respond to "Do Not Track" browser signals because no industry standard has been adopted, but where required by law (e.g., the California Global Privacy Control), we will honor opt-out signals to the extent applicable.
10. Security
We implement administrative, technical, and physical safeguards designed to protect your personal information, including encryption in transit (HTTPS), secure password hashing, restricted access controls, and routine review of our systems. Card data is handled exclusively by our PCI-DSS-compliant payment processor; we do not store full card numbers, CVCs, or expiration dates. No system is 100% secure, however, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.
If we become aware of a security incident that affects your personal information, we will notify you and any required authorities as required by applicable law.
11. Children's Privacy
The Service is intended for users who are at least 13 years of age. We do not knowingly collect personal information from children under 13. If we learn that we have collected information from a child under 13 without verifiable parental consent, we will delete it as soon as possible.
If you are a parent or guardian and believe your child under 13 has provided us with personal information, please contact us immediately at [email protected]. For users between 13 and 17, we encourage parental or guardian involvement and consent, particularly for any purchase or Entry Fee payment.
12. International Users
SEF is based in the United States. If you access the Service from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States and in any country where our service providers operate. The data protection laws in those countries may differ from those in your country. By using the Service, you consent to such transfers.
Where required by applicable law (e.g., the EU/UK GDPR), we rely on appropriate safeguards, such as Standard Contractual Clauses, to protect personal information transferred internationally.
13. Third-Party Links
The Service may contain links to third-party websites or services (including our payment processor and external Competition resources). This Policy does not apply to those third parties. We encourage you to review their privacy policies before sharing information with them.
14. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated Policy on this page with a revised "Last updated" date and, where practicable, by additional notice such as email. Your continued use of the Service after the effective date constitutes acceptance of the updated Policy.
15. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us at:
- Email: [email protected]
- Entity: TJLim Co., LLC (d/b/a Student Excellence Foundation), a Wyoming limited liability company
- Mailing address: 30 N Gould St Ste N, Sheridan, WY 82801, United States