Privacy Policy

Last Updated: April 27, 2023


Trilogy Mentors Inc., dba Pearl (“Pearl,” “we,” “our”) is located and registered in the Commonwealth of Virginia. Pearl offers education management and facilitation tools available online as subscription services (“Subscription Service”) as well as support and professional services (all collectively, the “Services”), and websites, including but not limited to,, and (collectively, the “Websites”).


Pearl is committed to protecting your privacy online. Our pledge is to safeguard any information we collect associated with you and your name, and will make every reasonable effort to use this information only as you request.

This Privacy Policy applies to the website (the “Site”, or “Service”) as well as Pearl’s web based software application (“App”). This Privacy Policy describes how we collect, use, share and secure the personal information you provide, as well as the information about our customers’ customers or end users that we process on behalf of our customers. It also describes your choices regarding use, access, correction and deletion of your personal information.


1. How We Collect Your Information

Information that you provide to us about yourself

In connection with accessing or using our Service, we may collect information from you which can be used to identify you (“Personal Information”), such as your name, business name and address, email address, phone, and other information about your business. Some of this information is required to use the Service.

We collect information when you register or open an account, sign in, pay a bill, purchase a Service, call us for support, or give us feedback.

We also collect non-personally identifiable information (“Non-PII”) including any information from which your identity is not readily ascertainable, and may include your internet protocol (or “IP”) address, browser, operating system, pages or content you access while visiting or using the Site and App and the date and time of such access.  In addition to you voluntarily providing us Non-PII, [Non-PII is automatically collected through the Site and App.]

Information you provide to us about your customers, employees, and end users

For the provision of our Service to you, you provide us with information which may identify your customers, employees, or end users (“electronic records”).

When you provide personal information about your customers, employees, or end users we will only use this information for the specific reason for which it is provided.

Information collected automatically

We use the electronic records to compile statistics about how collectively our visitors interact with our Website and web-based software application. These statistics contain no personal information and are only used by the Pearl technical support staff.

We may collect information through our Site by way of cookies or other tracking technologies. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. Our cookies do not contain any personally identifying information. Most web browsers automatically accept cookies, but you can usually change your browser to prevent that. Even without cookies, you can access certain public-facing pages of our site. However, session cookies are required to login to your account.

2. How We Use Your Information

Pearl will not sell, exchange, or give your information collected online to a third party. To the extent EU data protection law applies to our processing of information about you, we act as the “data controller”. To the extent EU data protection law applies to our processing of your customer or end user data, you serve as the “data controller” or “data processor” and we serve as the “data processor” or “data sub-processor”.  For instance, we may use or disclose your information for purposes of:

  • Responding to inquiries and fulfilling requests for information about Pearl and our projects and services, including information you ask to receive by signing up for [newsletters and alerts]
  • Providing web and email content that reflects your interests, informing you about events, and targeting content and communications to you
  • Preventing malicious activity and unwanted communications and ensuring website security
  • Performing data analysis, audits, and fraud monitoring and prevention to enhance and improve our Site and App, identify usage trends, determine program effectiveness, and carry out and expand our business activities

To Provide the Service:

We use your information to identify you, process your payments, provide you with technical support and assistance; and communicate with you about the Services via email. For example we will contact you to notify you of any issues with the Services or any suspicious activity in your account. The legal basis for these uses is the performance of the contract with you.

To Optimize or Improve the Service:

We use your information to authenticate you, prevent fraud and abuse of our Services, get feedback, and perform research. The legal basis for these uses is our legitimate interest in the improvement and optimization of our service offerings and in ensuring the security of our services and we apply appropriate safeguards to protect your information.

3. How We Share Your Information

We share information with service providers, as required by law, and in connection with the protection and enforcement of our legal and contractual rights.

With Service Providers:

We may share some of your information with third parties who provide services on our behalf to help with our business activities. This includes the use of third party software for the following: payment processing, sending emails, sending text messages, providing customer service, sending marketing communications (this does not include information about your customers), conducting research and analysis and providing cloud computing infrastructure. The legal basis for sharing this information is our legitimate interest in providing our Services efficiently and we implement careful measures to safeguard your information. We may share information as follows:

  • With our employees who need the information for the purposes described above
  • With third-party vendors and service providers who provide [cloud storage, website hosting, data analysis, payment processing, information technology, auditing and similar services related to our business]
  • With businesses that we acquire, are acquired by, or with which we merge or partner
  • When we believe disclosure is necessary and appropriate to prevent physical, financial or other harm, injury or loss, including fraud
  • To prevent against misuse or unauthorized use of our Site and App
  • With governmental or judicial authorities as required or ordered by those authorities or applicable laws or regulations
  • In connection with legal action, such as response to subpoenas or investigation of suspected illicit or illegal activities
  • Where we are bound by contract or law to enable a client or business partner to comply with applicable laws
  • With your consent or at your direction, such as when you choose to share information or publicly post content and comments on our Site
  • In the event of bankruptcy proceedings

With Public Authorities or Law Enforcement:

In certain situations, Pearl may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law (such as to comply with a subpoena or other legal process), when we believe in good faith that disclosure is necessary to protect our rights, to protect your safety or the safety of others, to investigate fraud, to respond to a government request, if we are involved in a merger, acquisition, or sale of all or a portion of our assets, or if we are involved in a bankruptcy or liquidation proceeding. The legal basis for this is our legitimate interest in protecting our legal rights and those of others, compliance with legal obligations and our legitimate interest in fulfilling legal obligations imposed by legal authorities,

4. Rights & Choices With Respect to Your Information

You can view and edit information that identifies you online through your Pearl account. You have a choice about the use of information that identifies you, marketing communications you receive from us, and in some cases our use of cookies.

Managing Marketing Communications From Us

We do not wish to send you any unwanted email, and have tried to make it easy for you to unsubscribe from any service you have requested. If you are receiving email announcements of our new features and updates, and wish to stop receiving them, you can click the “Unsubscribe” link in the footer of the e-mail.

Updating Your Personal Information

In connection with your right to manage your Personal Information that you provide to us, you may access, update, change, correct or request deletion of your information either through the Service or through our customer support.

Upon request we will provide you with information about whether we hold any of your personal information. You may access, correct, obtain a copy of or request deletion of your personal information by logging into your account or by contacting us at the contact information below. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Pearl acknowledges that you have the right to access your personal information. Pearl has no direct relationship with your customers or end users whose personal data it processes. An individual that is a customer, employee or end user of a Pearl client who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Pearl client (the data controller) with whom they have a relationship. If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

5. Data retention

We safely retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.  

At the termination, cancellation, or otherwise end of an organization’s subscription to the Pearl platform, Pearl will delete all content in accordance with our automated deletion schedule and back-up policy, but not sooner than 30 days after the termination of the service unless otherwise requested by the organization administrator.

At any time, organization administrators or platform users may request that their data be deleted, whichPearl will comply with within 30 days. Data deletion requests can be sent to

Do not send us any information, ideas, suggestions, proposals or comments that you consider confidential or that you wish to be treated as confidential.

6. Security

We provide reasonable and appropriate security measures in connection with securing Personal Information we collect. For example, we:

  • Constantly work to update our security practices to implement accepted best methods to protect your Personal Information, and review our security procedures carefully.
  • We use encryption for all connections to the Site for transmitting information
  • Train our staff and require them to safeguard your data.
  • Do not store any payment card data on our servers.

7. International Data Transfers

If you are using the Service from outside the United States, please be aware that you are sending information to the United States where our servers are located. Our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy. The Site’s servers are hosted by Amazon Web Services (“AWS”) in the United States and all data falls under protection per AWS’s service level agreement.

8. Changes to Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective.

9. Children Under the Age of 18

Our Site and App may be used by a child under the age of 18, but only if we obtain permission from the parent or legal guardian of the child wishing to use our Site and App pursuant to our Terms & Conditions.

10. Your Rights

You have the right to be informed of the personal information we process and the right to rectification/correction, erasure and restriction of processing. You also have the right to request from us a structured, common and machine-readable format of the personal information you provided to us. To exercise any of the rights mentioned in this Privacy Policy and/or in the event of questions or comments relating to the use of personal data you may contact us at [insert email].  In addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction.

Your California Privacy Rights (For California Residents Only)

Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of customers’ personal information with third parties.  These businesses are required to accept requests for disclosures of these policies from customers but are only required to honor one request per calendar year.  Businesses have thirty (30) days to respond to each inquiry to the designated address.  Each inquiring customer will receive an explanation of the categories of customer information shared and the names and addresses of any third-party businesses.  In limited circumstances, customers’ failure to submit requests in the manner specified will not require a response from the business.

If you are a California resident, you may request such information from us by sending a letter to the address listed below.  In your letter, please provide your name, address and email address, as well as a request that we provide such information to you, by using the following or similar language, “I request that Channel Clinical provide its third party information sharing disclosures required by section 1798.83 of the California Civil Code.”

10. How to Contact Us

If you have concerns about your privacy with the Site or App, please tell us by submitting an email to

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