Privacy Policy

Website Privacy Policy

This privacy policy (“Privacy Policy”) describes how Cotulla AcquisitionCo LLC and its subsidiaries and affiliates (collectively, “Cotulla” or “we” or “us”) collects, uses, and discloses the Personal Information we collect through this website and any related websites, applications, tools, or platforms (together, the “Site”), as well as through any other means where a link or reference to this Privacy Policy is provided at the time of collection. For purposes of this Privacy Policy, “Personal Information” means any information which directly or indirectly identifies or otherwise relates to a living individual person or household.

By visiting the Site, you agree to this Privacy Policy, which may be updated by us at any time. You should review this Privacy Policy carefully. If you do not understand or agree with it, you may not access or use the Site. By accessing and using the Site, you confirm that you understand and agree with the provisions of this Privacy Policy. Please note that if you do not provide certain Personal Information to us when requested, we may not be able to provide you with access to all areas of the Site.

California residents, please read our Supplemental California Privacy Policy.

What Personal Information do we collect?

We collect the following categories of Personal Information listed below about you in connection with your access and/or use of the Site.

  1. Personal Information you voluntarily provide to us.
    1. Identifiers and verification information. We collect Personal Information from you when you register on the Site, place an order, subscribe to our newsletter, respond to a survey, or fill out a form, including your name, e-mail address, mailing address, or phone number. 
    2. Communications information. We collect Personal Information that you provide when you contact us for any reason, such as to express an interest in obtaining additional information about the Site. 
    3. Employment and educational information. We may collect Personal Information you provide including job title, company name, school name, work phone number, and work email address.
  2. Personal Information from third parties. We may collect Personal Information from you and from third parties in connection with performing diligence on job applicants, service providers, and business partners. This data may include contact details, information concerning business practices, creditworthiness, reputation and business history, and job titles or roles.
  3. Information collected automatically through the Site. We may use cookies and other data collection technologies (e.g., session and persistent cookies, flash cookies, web beacons), and electronically gather information about the technology you use to access the Site and the areas of the Site you visit. We use cookies to keep track of advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors.

What do we use your Personal Information for?

We may use your Personal Information for the following purposes:

  1. To personalize your experience on the Site and help us to better respond to your individual preferences.
  2. To improve the Site and offerings based on the information and feedback we receive from you.
  3. To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs).
  4. To process transactions.
  5. For any other purposes, without your consent (except where such consent is required for the express purpose of delivering the product or service requested).
  6. To administer a contest, promotion, survey, or other features of the Site.

How do we protect your Personal Information?

We implement a variety of security measures to maintain the safety of your Personal Information when you place an order or enter, submit, or access your Personal Information through the Site. However, we cannot guarantee the security of your personal and other information or the appropriateness of the measures we use to safeguard such information. Please keep in mind that no information system can be 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. We are not responsible for circumvention by any third party of any privacy settings or security measures contained within the Site.

Do we disclose any of your Personal Information?

We do not share Personal Information with other people or nonaffiliated companies except when we have your permission, as required by law, and/or under the following circumstances:

  1. We work with trusted third parties, including service providers, who assist us in operating the Site, conducting our business, or servicing you. To the extent it is necessary, these third parties may have access to or process Personal Information about you. We take reasonable steps to require such third parties to maintain your Personal Information as confidential.
  2. We may disclose your Personal Information to comply with the law, enforce our Site policies, or protect ours or others’ rights, property, or safety.
  3. We may transfer or assign your Personal Information if we are acquired by or merged with another company, or in the unlikely event of bankruptcy.
  4. We may also disclose information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable laws. Such information may be provided to other parties for marketing, advertising, or other uses.

Do Not Track Signals

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals. 

Children’s Online Privacy Protection Act

The Site is not designed for, intended to attract, or directed toward children under the age of thirteen (13), and we do not knowingly collect any Personal Information directly from anyone under thirteen (13) years of age through the Site.

International Visitors

This Site is controlled and operated in the United States. If you choose to access the Site from outside the United States, you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing.

Our Contact Information

If you have any questions or comments about this Privacy Policy or our practices in relation to your Personal Information, you can email us at connect@cotullaeducation.com or call us at (877) 604-2121.

This policy was last modified on: September 22, 2025.

Supplemental California Privacy Policy

Last Updated: September 22, 2025

This privacy policy for California residents (this “California Policy”) is provided in addition to the information in the Website Privacy Policy provided by Cotulla AcquisitionCo LLC (“Cotulla,” “we,” or “us”), and explains our online and offline collection, use, and disclosure of Personal Information (as defined by the CCPA) relating to residents of the State of California (collectively, “you”) covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, together with any applicable regulations (all together, the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Policy. This California Policy is available in alternative formats upon request. Please email us at connect@cotullaeducation.com or call us at (877) 604-2121 to request an alternative format.

We may amend this California Policy from time to time, and will provide you with such amendments in the same manner in which you have received this California Policy. 

  1. Notice of Collection, Use, Retention, and Disclosure of Personal Information.
    1. Sale and Sharing of Personal Information. We utilize certain third party cookies and other tracking technologies that may come within the definition of a “sale” or “sharing” of personal information under the CCPA. You can learn more about our use of cookies and opt out of such sales or sharing of your personal information here. Apart from such cookies and tracking technologies, we do not and have not sold any categories of Personal Information to third parties. We do not and have not shared Personal Information with third parties for those third parties’ own direct marketing purposes, or shared any categories of Personal Information for the purpose of cross-context behavioral advertising.
    2. Categories of Personal Information. We may collect the following categories of Personal Information about you in connection with your access and/or use of the Site:
      1. Identifiers, including your name and contact details (e.g., address, email address, phone number), signature, date of birth, physical characteristics or description, state identification card (including driver’s license) number, government-issued ID, passport number, national ID card, account username, credit card number, debit card number, or any other financial information, unique personal identifier (e.g., device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology), online identifier, Internet protocol address, and other similar identifiers;
      2. Protected Classifications, including under California or federal law, such as national origin, age, gender, citizenship status;
      3. Commercial Information, including your purchase information, products or services purchased, obtained, or considered, and other purchase histories or tendencies; 
      4. Internet or Other Electronic Network Activity Information, including your web browser and/or device type, hardware and software settings and configurations, the web pages or sites that you visit just before or just after visiting the Site, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the Site. This includes information about how you use and navigate the Site, including which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions with the Site;
      5. Geolocation Data, including the physical location of your device by, for example, using satellite, cell phone tower or wireless local area network signals;
      6. Employment Information, including your employment-related information and history;
      7. Education Information, including grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records;
      8. Inferences, including inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
      9. Other Information, including the information you create or provide to us, such as the content of your communications with us and/or with our representatives, service providers and affiliates, including in-person discussions, telephone conversations, and electronic or other communications.
    3. Collection, Sources, and Use of Personal Information. We have collected and used the following categories of Personal Information from the following sources and for the following business purposes during the twelve (12)-month period prior to the “Last Updated” date of this California Policy:
Categories SourcesBusiness Purposes 
Identifiers.Directly from you, including, for example, through this website and any related websites, applications, tools, or platforms (together, the “Site”), when you send us an email, fill out our forms, apply for a job, or otherwise contact or communicate with us;

From automated tracking technology and monitoring tools, including, for example, cookies that track your access and use of our Site and other online services;

From within Cotulla, including, for example, from our affiliates and/or entities owned or controlled by Cotulla;

From businesses that we are evaluating, including, for example, in connection with a potential investment or business opportunity;

From vendors, including, for example, background check providers, advertising vendors, other business partners;

From recruiting sources, including, for example, agencies, social media networks, and other publicly available sources; and

From service providers, including, but not limited to website developers, data storage and maintenance storage providers, email and telephone marketing providers, and other service providers.		Performing and providing the services that we offer;

Marketing purposes, including sending correspondences, analyzing trends, administering the Site, tracking users’ movements around the Site, and to improve the Site and to make it more useful to visitors;

Recruiting purposes, including the evaluation of candidates and onboarding process;

Auditing and verifications, including (i) auditing related to a current interaction with you and concurrent transactions; (ii) undertaking activities to verify the quality and effectiveness of services, managing and mitigating risk, assessing compliance with applicable laws, legal requirements, and our policies (including to maintain the privacy and security of our data), conducting internal audits or investigations, and obtaining legal advice or to establish, exercise or defend legal rights and compliance activities; (iii) and undertaking internal research for technological development and demonstration;

Short-term, transient uses;

Protecting our systems, including by detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity (including to protect our assets and to investigate or defend against any claims of illegality or wrongdoing or in response to a court order or judicial or other government subpoena or warrant), and debugging to identify and repair errors that impair intended functionality; and

To comply with legal obligations, such as in connection with a valid court order, judicial subpoena, or regulatory inquiry, and as required by law enforcement agencies, federal or state regulatory agencies or self-regulatory organizations.
Protected Classifications.Directly from you;

From automated tracking technology and monitoring tools;

From within Cotulla;

From businesses that we are evaluating;

From vendors;

From recruiting sources; and

From service providers.		Auditing and verifications; and

Complying with legal obligations.
Commercial Information.Directly from you;

From within Cotulla;

From businesses that we are evaluating; and 

From vendors.		Performing and providing the services;

Marketing purposes;

Recruiting purposes;

Auditing and verifications;

Protecting our systems; and

Complying with legal obligations.
Internet or Other Electronic Network Activity Information.Directly from you;

From automated tracking technology and monitoring tools; and

From service providers. 		Performing and providing the services;

Marketing purposes;

Recruiting purposes;

Auditing and verifications;

Short-term transient uses;

Protecting our systems; and

Complying with legal obligations. 
Geolocation Data.From automated tracking technology and monitoring tools; and

From service providers. 		Performing and providing the services;

Marketing purposes;

Recruiting purposes;

Auditing and verifications;

Short-term transient uses;

Protecting our systems; and

Complying with legal obligations.
Employment Information.Directly from you;

From automated tracking technology and monitoring tools;

From within Cotulla;

From businesses that we are evaluating;

From vendors;

From recruiting sources; and

From service providers.		Performing and providing the services;

Recruiting purposes;

Auditing and verifications;

Protecting our systems; and

Complying with legal obligations.
Education Information.Directly from you;

From within Cotulla;

From vendors; and

From recruiting sources.		Performing and providing the services;

Marketing purposes; and

Recruiting purposes.
Inferences.From automated tracking technology and monitoring tools;

From within Cotulla;

From businesses we are evaluating;

From vendors;

From recruiting sources; and

From service providers.		Performing and providing the services;

Marketing purposes;

Auditing and verifications; and

Protecting our systems.
Other Information.Directly from you;

From automated tracking technology and monitoring tools;

From within Cotulla;

From vendors; and

From recruiting sources. 		Performing and providing the services;

Marketing purposes;

Recruiting purposes;

Auditing and verifications;

Short-term, transient uses;

Protecting our systems; and

Complying with legal obligations.
  1. Children’s Information. The Services are not designed for, not intended to attract, or directed toward children under the age of sixteen (16). We do not knowingly collect Personal Information from users under the age of sixteen (16) without prior consent of a parent or guardian. If a parent or guardian becomes aware that his or her child has directly provided us with Personal Information, please contact us using the information at the bottom of this California Policy.
  2. Sensitive Personal Information. Sensitive Personal Information may include state identification card, driver’s license numbers, passport numbers, account credentials, debit card, or credit card number in combination with any required security or access code, and precise geolocation. To the extent we collect your Sensitive Personal Information, we will not use or disclose such information for purposes other than (i) to perform services/goods that you reasonably expect from us; (ii) to prevent, detect, and investigate security incidents; (iii) to resist illegal actions directed at the business and defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient uses; (vi) to perform services necessary for the business; (vii) to verify and maintain the quality and safety of our services; and (viii) generally for purposes that do not infer characteristics about you.
  3. Retention of Personal Information. We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected.
  4. Disclosures of Personal Information for Business Purposes. We may have disclosed the following categories of Personal Information to the following categories of recipients for the following business purposes during the twelve (12)-month period prior to the “Last Updated” date of this California Policy:
Business PurposesRecipientsCategories
Performing and providing the services.Affiliates, including, for example, Aviation Institute of Maintenance, Centura College, and Tidewater Tech;

Government entities, including, for example, state and federal governmental bodies;

Service providers, contractors, and other vendors, including website developers, web-hosting platforms, data storage providers, maintenance providers, and others who provide services to us or on our behalf; 

Professional service organizations, such as auditors, tax advisors and law firms; and

Investors and creditors, including, for example, prospective or current investors or creditors of Cotulla.		Identifiers;

Protected Classifications;

Commercial Information;

Geolocation Data;

Online Activity;

Employment Information;

Inferences; and 

Other Information.
Marketing purposes.Affiliates;

Service providers, contractors, and other vendors; and

Professional service organizations.		Identifiers;

Protected Classifications;

Commercial Information;

Geolocation Data;

Inferences; and

Other Information.
Recruiting purposes.Affiliates;

Service providers, contractors, and other vendors; and

Professional service organizations.		Identifiers;

Protected Classifications;

Commercial Information;

Geolocation Data;

Inferences; and

Other Information.
Auditing related to a current interaction with you and concurrent transactions.Affiliates;

Service providers, contractors, and other vendors;

Government entities;

Professional service organizations; and

Investors and creditors.		Identifiers;

Protected Classifications;

Commercial Information;

Geolocation Data;

Employment Information;

Inferences; and 

Other Information.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.Affiliates;

Service providers, contractors, and other vendors;

Government entities; and

Professional service organizations.		Identifiers; 

Protected Classifications;

Commercial Information;

Geolocation Data;

Online Activity;

Employment Information;

Inferences; and

Other Information.
Short-term, transient uses. Affiliates

Service providers, contractors, and other vendors; and 

Professional service organizations.		Identifiers; 

Protected Classifications;

Commercial Information;

Geolocation Data;

Inferences;

Online Activity; and

Other Information.
Debugging to identify and repair errors that impair existing intended functionality.Service providers, contractors, and other vendors.Identifiers;

Protected Classifications;

Commercial Information;

Geolocation Data;

Employment Information; and

Inferences.
Undertaking activities to verify or maintain the quality of our services. Affiliates;

Service providers, contractors, and other vendors;

Government entities; and

Professional service organizations;		Identifiers;

Protected Classifications;

Commercial Information;

Geolocation Data;

Employment Information; 

Inferences; and 

Other Information.
To comply with legal obligations.Affiliates;

Service providers and other vendors; 

Government entities;

Professional service organizations; and 

Investors and creditors.		Identifiers; 

Protected Classifications;

Commercial Information;

Geolocation Data;

Online Activity;

Employment Information;

Inferences; and 

Other Information.
In connection with business transactions.Affiliates;

Service providers and other vendors; 

Government entities;

Professional service organizations; and

Investors and creditors.		Identifiers;

Protected Classifications;

Commercial Information;

Geolocation Data;

Online Activity; 

Employment Information

Inferences; and 

Other Information.
  1. Anonymous and Aggregated Data. Cotulla may share anonymous or aggregated data in order to facilitate our business operations. To the extent such data constitutes anonymized or de-identified data under the CCPA and other applicable privacy and data protection laws, we will maintain and use such data without attempting to re-identify the data.
  2. No Automated Decision-Making. We do not use computer algorithms to make automated decisions based on your Personal Information. We may process some of your Personal Information automatically, with the goal of assessing certain personal aspects related to you (profiling), in order to comply with our legal or regulatory obligations.
  1. California Privacy Rights
    • If you are a California resident, you have certain choices regarding our use and disclosure of your Personal Information, as described below.
      1. Your CCPA Privacy Rights
        1. Know: You have the right to request, twice in a twelve (12)-month period, that we provide (1) certain information about (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which the Personal Information is collected; (c) the business or commercial purpose for collecting your Personal Information; and (d) the categories of third parties with whom we have shared your Personal Information; and/or (2) the specific pieces of Personal Information we have collected, used, and disclosed about you during the past twelve (12) months.
        2. Deletion: You have the right to request that we delete certain Personal Information we have collected from and about you and to tell our service providers to do the same.
        3. Correction: You have the right to request that we correct or amend certain Personal Information we maintain about you if it is inaccurate. 
        4. Limit: You have the right to request that we limit the use and disclosure of Sensitive Personal Information we have collected. To the extent we collect any Sensitive Personal Information from or about you, we will use it only for the purposes listed above in Section 1(E). As such, any Sensitive Personal Information that we collect does not come within this right to limit use and disclosure.
        5. Opt-Out: You have the right to opt-out of the sale of your Personal Information to third parties and/or the sharing of your Personal Information for certain purposes. As noted in Section 1(A) above, Cotulla does not sell or share Personal Information to or with third parties.
        6. Non-Discrimination: You have the right not to experience discriminatory treatment, and we will not discriminate against you or retaliate against you because you have exercised any CCPA privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.
      2. How to Submit a Request. If you are a California resident and you wish to exercise any of the rights enumerated in this Section 2, please email us at connect@cotullaeducation.com or call us at (877) 604-2121.
      3. Verifying Your Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
        1. Verification Process. If you request to know, access, delete, and/or correct your Personal Information, we may require you to provide any of the following information: address, date of birth, unique personal identifier, state of residence, telephone number, email address, or details of a transaction. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the individual whose Personal Information is the subject of the request. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity.
        2. Authorized Agent. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent written permission to do so (e.g., via a notarized letter), and (2) verify your own identity directly with us (as described above) and confirm with us that you provided the authorized agent permission to submit the request.
      4. Additional California Privacy Disclosures.
        1. Do Not Track Signals. Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.
        2. Shine the Light Notice. California residents have the right to request and obtain from us, once a year and free of charge, certain information about the categories of their Personal Information (if any) that we disclosed to third parties for direct marketing purposes, including the names and addresses of all third parties with whom we shared your information for direct marketing purposes in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in Section 2(B), above.