Prulu, Inc. ("Prulu" or "we") has created this privacy policy ("Policy") in order to demonstrate our commitment to customer privacy. Privacy on our Site and in providing our Service is of great importance to us. Because we gather important information from our visitors and customers (collectively, "Users"), we have established this Policy as a means to communicate our information-gathering and dissemination practices.

By using or accessing our Site and using the Service, you agree to our privacy policy outlined here.

We are dedicated to establishing a relationship of trust with our Users, based on respect for personal identity and information and by promoting the use of fair information practices. This privacy policy covers all web properties owned and maintained by us, including but not limited (collectively, the "Site") and the Service. Because we want to demonstrate our commitment to our Users' privacy, we are disclosing:
  • What information we collect.
  • How we use the information, and with whom we share User Information.
  • What choices are available to Users regarding collection, use and distribution of the information, and how Users can correct any inaccuracies in the information.
  • What types of security procedures are in place to protect against the loss, misuse or alteration of information under our control.


We are only responsible, on a limited basis, for our proprietary applications provided to our Users as part of the Service. We are not responsible for information accessed through our Service or open-source or third-party applications provided with the Service. We specifically disclaim any responsibility for User Content – please see "User Content" below.

Regarding Children

We do not intentionally gather personal information from anyone under the age of 13, or knowingly allow such persons to register as Users. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us at

We collect two types of information from our Users: Personal Information and Anonymous Information. "Personal Information" means information that allows someone to identify or contact you, including, for example, your name, address, telephone number and e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. "Anonymous Information" means data that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individual persons.

We collect Personal Information and Anonymous Information in the following ways:

Information You Provide to Us

When you register as a User of the Service, you are required to give Personal Information (such as full name, profile photo, email address, and your registration in a particular class at a particular University), and a unique identifier (password). You might also provide Personal Information if you provide us feedback or otherwise contact us via e-mail. We collect other types of Personal Data that you provide to us voluntarily, such as operating system and version and other requested information if you contact us via e-mail regarding support for the Services.

In addition, your participation on Prulu will also produce information that will be personally identifiable, such as the questions and answers you post and what times you participate on Prulu.

To provide the Services, we might require you (a) to provide Personal Data about yourself and (b) to provide Personal Data about other users. You represent and warrant that your provision to us of such Personal Data does not violate any provisions of the Family Education Rights and Privacy Act ("FERPA").


Occasionally, we request information from Users via surveys. Participation in these surveys is completely voluntary, and the User therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code). Survey information will be used for purposes of monitoring or improving the use or and satisfaction with the Service. Though we may use an intermediary to conduct these surveys, we require that they not use Users' personally identifiable information for any secondary purposes.

User Content

When you post messages on the message boards of our Site will automatically post with your name. The information contained in your posting, including any Personal Information, will be stored on our servers and other Users will be able to see it. Please see "User Content" below.

Information Provided by the University or Instructor

Your University or your Instructor may also provide us with your name, email address, and other information when enrolling you in a Class on the Service.

Information Collected via Technology

Our servers (which may be hosted by a third-party service provider) collect Anonymous Information and Personal Information from you, including browser type, operating system, Internet Protocol (IP) address (which might vary from session to session), domain name, and/or a date/time stamp for your visit.


We may receive data from our Users as part of the communication connection itself, that is, the standard electronic greeting between the User's computer or mobile device and our servers. This information often consists of network routing, equipment information (device or browser type), location, date and time. We use cookies and navigational data like Uniform Resource Locators (URLs) to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed.

"Cookies" are small pieces of information that a website sends to your computer's hard drive while you are viewing a web site. Standing alone, cookies do not identify the User personally; they merely recognize the User's browser. The only Personal Information a cookie can contain is information the User supplies. A cookie can't read data off the User's hard disk or read cookie files created by other websites.

Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from the User's computer when he closes his browser software or turns off his computer. Persistent cookies remain on the User's computer after he has closed his browser or turned off his computer. They include such information as a unique identifier for the User's browser. Persistent Cookies can be removed by following Internet browser help file directions. If you choose to disable Cookies, some areas of our Site may not work properly.

We use session cookies containing encrypted information to allow the system to uniquely identify the User while he is logged in. This information allows us to process our Users' online transactions and requests, to enhance security and to improve the functionality of the Site by avoiding duplicate data entry, and facilitating navigation. Session cookies help us make sure the User is who he says he is after he has logged in and are required in order to use the Service. We use persistent cookies, which only we can read and use, to identify the fact that the User is a Prulu User or prior visitor to our Site, as the case may be. We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store passwords in persistent cookies.

While we do not offer an opt-out on the Site for cookies, browsers provide you with information about and control over cookies. If you disable your web browser's ability to accept cookies, your access to and usage of the Service could be denied.

Log Files

When you use the Service, we automatically receive and record information on our server logs from your browser or mobile platform, including your location, IP address, cookie information, and the page you requested. In addition, we use log files to track data stored using the Service to the appropriate User. Except for the purpose of tracking Users' message posting frequency, and other information required to enhance your usage of the Service, information gathered from log files, such as IP addresses, are not linked to Personal Information.

Clear Gifs

We may employ clear gifs (also known as web beacons) to track the online usage patterns of our Users. This information is Anonymous Information; no Personal Information is collected using these clear gifs. In addition, we may also use clear gifs in HTML-based emails sent to our Users to track which emails are opened by recipients. The information is used to enable more accurate reporting, improve the effectiveness of our marketing, and make the Service better for our Users.


Limited Disclosure of Personal Information to Third Parties

We are committed to protecting the privacy of our Users. We will not, under any circumstances, rent, sell, or give away Personal Information, nor will we trade or exchange mailing lists with any other organization. We will not monitor, edit, or disclose the contents of Personal Information.

However, we may share your Personal Information with third parties for the purpose of providing the Service to you. If we do this, such third parties' use of your Personal Information will be bound by this Privacy Policy.

Notwithstanding the foregoing, we may disclose Personal Information to third parties if we believe that such action is necessary to (1) enforce the Terms of Use, (2) comply with applicable law, (3) comply with a current judicial proceeding, a court order or other legal process, (4) protect and defend our rights or property, or (5) act under exigent circumstances to protect the personal safety of our Users or the public.

Please note that we may store Personal Information in locations outside of our direct control (for instance, on servers or databases co-located with hosting providers).

Disclosure of Personal Information in the Use of the Service

We will display some of your Personal Information, such as your name, to Class Members or in the course of limited demonstrations of the Service. User Content you post will become available for other Members to view and to edit. Instructors have access to the User Content and certain Personal Information of all Class Members. Please see "User Content" below.

Internal Use of Personal Information

We receive and store Personal Information for such purposes as allowing you to set up a User account that can be used to interact with other Users through the Service, measuring and improving the Service, customizing the advertising and content you see, and communicating with you about specials and new features.. We may also draw upon this Personal Information in order to adapt the Services to the needs of our Users, to research the effectiveness of our Services, and to develop new tools for the Service.


Although we currently do not have a parent company or any subsidiaries, joint ventures, or other companies under common control (collectively, "Affiliates"), we may in the future. We may share Personal Data with these Affiliates, in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company or our assets, that company will possess the Personal Data collected by it and us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy, as it might be amended.

Communication from the Service

We will not send our Users excessive amounts of email or other communications. However, we might, from time to time, send to our Users emails containing the following types of information: notifications concerning the status or expiration of the User's account; activity status reports; service and software upgrade notices; Service usage tips, notices concerning new Service features and the pricing of our Services (but not those of any other party); and requests for feedback on the User's use of the Service. Users may opt-out of receiving many of such notices. Please see the "Opt-out" section below.

Service Announcements

We communicate with Users on a regular basis to provide requested support services and regarding issues relating to their accounts. We make such communications via email or phone (if you provide your telephone number). Personal Information and Anonymous Information may at times be viewed or accessed for the purpose of resolving a technical problem, a support issue, or a suspected violation of the Terms of Use.


Certain information about Users who are students is contained in records maintained by us and that this information can be confidential by reason of FERPA and related University policies unless valid consent is obtained from the University's students or their legal guardians. We will protect these records in accordance with FERPA and University policy. The University will advise us when any Users have provided consent to release information to an extent broader than as provided for by FERPA or University policy.

Disclosure of Anonymous Information to Third Parties

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to disclose Anonymous Data to third parties at our discretion.

Internal Use of Anonymous Information.

We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses; (f) help you efficiently access your information after you sign in; (h) track User Content and Users to the extent necessary to comply as a service provider with the Digital Millennium Copyright Act; and (i) gather broad demographic information for aggregate use.

Disclosure and Use regarding Illegal Activities.

We will use both Personal Information and Anonymous Information to prevent potentially illegal activities and to enforce our Terms of Use. We use a variety of technological systems to detect and address anomalous activity and screen content to prevent abuse such as spam.



We offer our Users a means to choose how we may use Personal Information. If, at any time after registering with the Service, you change your mind about receiving information from us or about our use of your Personal Information as provided in this Privacy Policy, you can send us a request specifying your new choice by emailing When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly at However, you may not opt out of notices of any updates to our Terms of Use or Privacy Policy.

Managing Personal Information

If your Personal Information changes (such as phone number or email address), you can correct or update your Personal Information by following the instructions at

Deleting your Account

Should you ever decide to terminate your User account, you may do so by clicking on the "delete account" link on your account settings page. If you terminate your account, your profile, including your User Content, will be removed from the site and deleted from our servers. Because of the way we maintain our servers and our Service, such deletion may not be immediate, and residual copies of your profile information or posts may remain on backup media.

Even after you remove information from your account or profile, copies of that information may remain viewable elsewhere, to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or it was copied or stored by other users. Removed and deleted information may remain on backup media for an undetermined period prior to being deleted from our servers.

We process and host information provided by Users User Content for our Users, but we do not control Users' information collection or use practices related to the User Content. We make no independent use of the User Content outside of what is needed to provide the Service. Prulu reserves the right, but has no obligation, to monitor the User Content you post on the Service. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Use, or to protect or defend our rights or property or those of any third party. Prulu also reserves the right to remove information upon the request of any third party.



Our Site and the Service contain links to other web sites. These links are provided for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our Site and go to another website. During this process, another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links/apps to such outside websites.

Notification of Changes

Prulu may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we use Personal Information, we will notify you by posting an announcement on our Service or sending you an email. Users are bound by any changes to the Privacy Policy when they use the Service after such changes have been first posted. We encourage our Users to check this Policy whenever they use the Service to see if it has been updated since their last visit.


We contract with a third party to provide and manage the servers that are required to provide the Service and on which Users' personal information and Data is stored. The third-party provider has ensured us that their service is hosted in a secure server environment that uses a firewall and other advanced technology to prevent interference or access from outside intruders. While we have taken efforts to guard our Users' personal information, we cannot ensure or guarantee that such information will not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others. Each User transmits such information to us and uses the Service at his own risk.

When you register as a User, you will provide an individual User ID and password. To protect the confidentiality of your Personal Information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of our Site and Service by any person using your User ID and password. You must advise us immediately if you believe that your User ID and password have been misused.

International Users

Please note that Personal Information will be stored and processed on computers in the United States. The laws on holding personal data in the United States may be less stringent than the laws of other countries. United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in the United States. Your use of this site or the Service or your submission of any Personal Information to us will constitute your consent to the transfer of your Personal Information outside of your home country, including the United States, which may provide for different data protection rules than in your country. If you object to his personal information being transferred or used as described in this Policy, you should not register for the Service.

This Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Questions or concerns regarding this Policy should be sent to our security administrator at